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Issues: (i) Whether, where the assessee follows the cash system of accounting, outstanding fees remaining unrecovered on the valuation date form part of the assessee's net wealth. (ii) If so, whether such outstandings are to be included at gross value or at their discounted value after accounting for outstanding liabilities.
Issue (i): Whether, where the assessee follows the cash system of accounting, outstanding fees remaining unrecovered on the valuation date form part of the assessee's net wealth.
Analysis: The answer was governed by the binding view already taken on the valuation of professional outstandings under the Wealth-tax Act. On that basis, the existence of unrecovered fees on the valuation date did not take them outside the scope of net wealth merely because the assessee maintained accounts on cash basis.
Conclusion: This issue was answered in the affirmative and against the assessee, in favour of the Revenue.
Issue (ii): If so, whether such outstandings are to be included at gross value or at their discounted value after accounting for outstanding liabilities.
Analysis: The correct value of the outstandings was held to depend on the material on record, and if necessary on additional material permitted to be brought before the Tribunal. The Tribunal was directed to determine whether the gross outstandings required discounting, including consideration of bad debts and related factors, in the light of the governing decisions.
Conclusion: The question was not finally quantified by the Court and was remitted to the Tribunal for fresh determination.
Final Conclusion: The inclusion of unrecovered fees in net wealth was upheld, but the valuation question was sent back for determination by the Tribunal on the evidence.
Ratio Decidendi: Under the Wealth-tax Act, receivables outstanding on the valuation date may form part of net wealth even under the cash system of accounting, while their precise value must be determined on the basis of relevant material and discounting principles, if applicable.