- (1.) The dispute in this appeal relates to the value of 850 shares held by the deceased in the Engle Lithographing Co. (P.) Ltd. for the purpose of computation of net principal value of his estate.
(2.) Assistant Controller chose to value the shares on the method of break-up value but in so doing he added a sum of Rs. 16,07,800 as goodwill of the company on the basis of three years super profits instead of Rs. 16,368 shown in the balance sheet. He also did not choose to follow the method prescribed in rule ID of the Wealth-tax Rules, 1957 (the 1957 Rules) and, consequently did not grant 15 per cent reduction in the break-up value as provided for therein.
(3.) On appeal, the Appellate Controller upheld the valuation of the Assistant Controller except for the purpose of determining the goodwill he took the rate of capitalisation at three times of the average profit of three years which resulted in a reduction of Rs. 5,35,943 from the total assets of the company. The accountable person has come up in second appeal before us.;