Wealth-tax valuation date rule bars reopening a concluded assessment based on a later sale price.

Wealth-tax liability must be determined by the property's value on the relevant valuation date, not by a later sale price realised after that date. A subsequent market realisation does not justify reopening a concluded assessment to substitute the later sale proceeds for the earlier valuation. The Tribunal was therefore correct in rejecting reassessment on that basis, and the issue was answered in favour of the assessee and against the Revenue.

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Issues: Whether the Revenue could reopen a concluded wealth-tax assessment for the assessment year 1982-83 and substitute the later sale price of the property for its value as on the relevant valuation date.

Analysis: Wealth-tax is chargeable on net wealth as on the valuation date relevant to the assessment year. A later sale fetching a higher price does not alter the value of the property for the earlier assessment year, nor does it justify reopening a concluded assessment to adopt a subsequent market realization as the earlier valuation. The Tribunal was therefore right in rejecting the attempt to reassess the property on the basis of its later sale price.

Conclusion: The question was answered in favour of the assessee and against the Revenue.

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