JUDGEMENT
DIPAK KUMAR SEN, J. -
(1.) THIS consolidt. reference arises out of wealth-tax assessments of Surendra Paul, the assessee, for
the assessment years 1960-61 to 1972-73, the relevant valuation dates being 31st March of the
calendar years 1960 to 1972. On an application of the Revenue under s. 27(1) of the WT Act,
1957, the Tribunal has referred the following questions as questions of law arising out of its order for the opinion of this Court:
Assessment years 1960-61 to 1972-73
"Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that in determining the valuation of the interest of the assessee in the partnership firm of M/s Aminchand Pyarelal, of which the assessee was a partner, the provisions of s. 4(1)(b) and s. 7 (1) of the WT Act, 1957, were applicable and the provisions of s. 7(2)(a) of the WT Act, r/w rr. 2A to 2G are not applicable ?"
(2.) ASSESSMENT years 1960-61 to 1965-66 :
"Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the income-tax liabilities of Rs. 15,01,200 arising on the basis of the disclosure made by the firm of Aminchand Pyarelal, of which the assessee is a partner, under s. 68 of the Finance Act, 1965, and under s. 24 of the Finance (No. 2) Act, 1965, have to be deducted from the net wealth of the said firm in respect of the asst. yrs. 1960-61 to 1965-66 for the purpose of determining the value of the partnership interest of the assessee ?"
Assessment years 1963-64 to 1966-67 :
"Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the personal income-tax liabilities of Rs. 90,000 arising from the disclosure made by the assessee under s. 68 of the Finance Act, 1965, would be deductible in computing the net wealth of the assessee in respect of the asst. yrs. 1963-64 to 1966-67 ?"
(3.) SO far as the common question referred for the asst. yrs. 1960-61 to 1965-66 is concerned, the controversy raised therein is covered by a decision of this Court in CWT vs. V. K. Manseta (1983)
143 ITR 205. Following the said decision, we answer the question in the affirmative and in favour of the assessee.;
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