Procedural valuation rules in Schedule III apply to pending wealth-tax assessments, leaving no separate referable question of law.

The amended valuation provisions in Schedule III of the Wealth-tax Act, 1957 were treated as procedural in character and therefore applicable to pending assessment proceedings. On that basis, market value was to be determined under the law in force when the assessment was made, and the Tribunal was justified in directing adoption of Schedule III. The settled Supreme Court position on the procedural nature of the valuation rule meant that no independent referable question of law survived for consideration.

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Issues: Whether the amended valuation provisions in Schedule III of the Wealth-tax Act, 1957 applied to a pending assessment and whether any referable question of law arose from the Tribunal's direction to adopt that schedule.

Analysis: The valuation provisions in Schedule III were treated as procedural in character and akin to rules of evidence. Procedural law applies to pending matters, and market value is to be determined according to the law in force when the assessment is made. The issue was concluded by the Supreme Court decision holding that the relevant valuation rule is procedural and applicable to pending proceedings. Once that position was settled, no independent referable question survived for consideration.

Conclusion: The amended Schedule III valuation provisions applied to the pending matter, and the Tribunal was justified in refusing to refer the question of law.

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