Valuation method amendments apply to pending wealth-tax proceedings when the change is procedural and not expressly excluded.

Amended valuation provisions and Schedule III under the Direct Tax Laws (Amendment) Act, 1989 were treated as procedural machinery for determining asset value under the Wealth-tax Act. Because the change prescribed the method or manner of valuation, it was held to apply to pending wealth-tax appeals relating to earlier assessment years, absent a clear contrary indication in the statute. The operative effect was that the amended valuation rules governed matters still pending when the amendment came into force, and the question was answered in favour of the assessee and against the Revenue.

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Issues: Whether the amended valuation provisions and Schedule III inserted by the Direct Tax Laws (Amendment) Act, 1989 apply to pending wealth-tax appeals for earlier assessment years.

Analysis: The valuation provision in section 7 of the Wealth-tax Act was treated as a machinery provision laying down the method of determining the value of assets other than cash. The court applied the principle that a rule or statutory amendment prescribing the mode of valuation is procedural in nature and, when so characterised, operates on pending matters. On that basis, the amended method of valuation introduced by Schedule III was held applicable to appeals that were still pending when the amendment came into force.

Conclusion: The amended valuation rules applied to the pending cases, and the question was answered in favour of the assessee and against the Revenue.

Ratio Decidendi: A statutory amendment prescribing the method or manner of valuation of assets is procedural and therefore applies to pending wealth-tax proceedings unless the enactment clearly indicates otherwise.

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