Valuation reference under tax law upheld where no arbitrariness was shown and writ interference was refused.

Valuation reference for the petitioners' properties under the wealth-tax and income-tax provisions was upheld because the Court found no arbitrariness or illegality on the facts presented. The reference was justified as being made to determine capital gains liability and deemed gift liability, and the respondents also relied on pending related assessment or reassessment proceedings involving a connected partner. The Court held that the authorities cited by the petitioners did not assist on these facts and found no ground for interference in writ jurisdiction.

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Issues: Whether the reference for valuation of the petitioners' properties under the wealth-tax and income-tax provisions was legal infirmity when proceedings were asserted to be pending, and whether such reference warranted interference in writ jurisdiction.

Analysis: The petitioners challenged the valuation reference as contrary to the statutory conditions for invoking the valuation provisions. The respondents justified the reference on the footing that it was made to determine capital gains liability and deemed gift liability, and also asserted that related assessment or reassessment proceedings were pending against a partner connected with the matter. On the facts pleaded and the material relied upon, the Court found no arbitrariness or illegality in the reference and held that the cited authorities did not assist the petitioners on the facts of the case.

Conclusion: The valuation reference was upheld and no ground for interference in writ jurisdiction was made out; the challenge failed.

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