Dipak Kumar Sen, A.C.J. - (1.) The above references respectively under Sections 27(1) and 27(3) of the Wealth-tax Act, 1957, are being heard together and are disposed of by this judgment.
(2.) The material facts found or admitted and the proceedings leading up to the above references are, inter alia, that one G.S. Atwal, since deceased, had acquired assets and properties, movable and immovable, during his lifetime out of his individual earnings. The said G.S. Atwal died intestate on January 28, 1961, leaving him surviving his four sons and his widow as his legal heirs and representatives. For the assessment years 1961-62 to 1965-66, J.S. Atwal, the eldest son of the deceased, filed returns of wealth as the karta of a Hindu undivided family, the assessee, consisting of the said four sons and the widow of the deceased. The assets and properties of the deceased were shown to belong to the said Hindu undivided family.
(3.) Assessments for the said assessment years 1961-62 to 1965-66 were completed on the basis of the returns filed as aforesaid treating the Hindu undivided family as the assessee. From the orders of assessments, appeals were preferred by the assessee before the Appellate Assistant Commissioner wherein the assessments were sought to be impugned on certain points including the valuation of the properties and assets. From the orders of the Appellate Assistant Commissioner, the assessee preferred further appeals before the Tribunal.;