Wealth-tax valuation must follow each assessment year's valuation date; earlier year report cannot bind later assessments.

Wealth-tax valuation must be determined separately with reference to the relevant valuation date for each assessment year, and a valuation report for an earlier year cannot automatically control later years. The Commissioner's direction to redo the assessments without binding the Assessing Officer to adopt the earlier valuation was therefore proper. The Tribunal erred in modifying that direction and in requiring the later assessments to be finalised on the basis of the value fixed for the prior year; the referred question was answered in favour of the Revenue and against the assessee.

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Issues: Whether the Appellate Tribunal was justified in modifying the Commissioner's direction under section 25(2) and in directing the Assessing Officer to finalise the wealth-tax assessments for later assessment years on the basis of the value fixed for an earlier assessment year.

Analysis: The valuation report obtained for an earlier valuation date could not automatically govern subsequent assessment years. Wealth-tax valuation has to be made with reference to the relevant valuation date for each assessment year, and a report pertaining to an anterior date does not, by itself, apply to later years. The Commissioner's direction to redo the assessments without binding the Assessing Officer to adopt the earlier valuation was, therefore, proper.

Conclusion: The Tribunal was not right in modifying the Commissioner's direction, and the answer to the referred question is in favour of the Revenue and against the assessee.

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