Wealth-tax valuation rule 1D applies with section 24(6), and a new objection cannot be raised for the first time later.

Section 24(6) of the Wealth-tax Act and rule 1D of the Wealth-tax Rules were treated as operating consistently, so no repugnancy arose and neither provision overrode the other. On that basis, arbitrators making a valuation in a reference under section 24(6) were required to apply rule 1D and could not ignore it. The Revenue was also held unable to rely on rule 1D at the reference stage because no specific objection had been raised before the Tribunal. The stated ratio is that a valuation rule aligned with the parent statute governs the process, and a new objection cannot be introduced later if it was not specifically taken earlier.

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Issues: (i) Whether section 24(6) of the Wealth-tax Act conflicts with rule 1D of the Wealth-tax Rules and whether the rule prevails over the statutory provision; (ii) whether, in a reference under section 24(6), the arbitrators are bound to apply rule 1D; (iii) whether the Revenue can rely on rule 1D in the absence of a specific objection before the Tribunal.

Issue (i): Whether section 24(6) of the Wealth-tax Act conflicts with rule 1D of the Wealth-tax Rules and whether the rule prevails over the statutory provision.

Analysis: The answers already given in the connected reference were followed. On that view, section 24(6) and rule 1D operate consistently and there is no repugnancy between them, so the question of one overriding the other does not arise.

Conclusion: There is no conflict between section 24(6) and rule 1D, and neither overrides the other.

Issue (ii): Whether, in a reference under section 24(6), the arbitrators are bound to apply rule 1D.

Analysis: Since rule 1D governs valuation and no conflict exists with section 24(6), the arbitrators cannot disregard it in making the valuation under the reference procedure.

Conclusion: The arbitrators are bound to follow rule 1D even in a reference under section 24(6).

Issue (iii): Whether the Revenue can rely on rule 1D in the absence of a specific objection before the Tribunal.

Analysis: The record did not show that the Revenue had raised any specific objection before the Tribunal that the valuation report was contrary to rule 1D. In those circumstances, the point could not be permitted to be urged for the first time at the reference stage.

Conclusion: The Revenue could not rely on rule 1D at that stage because no specific objection had been taken earlier.

Final Conclusion: The reference was answered by holding that rule 1D was applicable and binding, while the Revenue was not permitted to raise the valuation objection for the first time.

Ratio Decidendi: Where a valuation rule operates consistently with the parent statute, it must be applied in the statutory process, and a party cannot raise a new factual or legal objection at the reference stage if it was not specifically raised earlier.

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