Beneficial interest in trust corpus treated as part of net wealth under wealth-tax valuation principles.

An assessee's beneficial interest in a trust corpus on the relevant valuation date was held includible in net wealth. The Bombay High Court followed its earlier wealth-tax ruling on the same point and accepted that the assessee had such an interest in the trust corpus; that interest therefore formed part of the assessee's taxable net wealth. The questions were answered in the affirmative and against the assessee, with the Revenue succeeding.

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Issues: Whether the assessee had any interest in the trust corpus on the relevant valuation date and, if so, whether it was includible in the assessee's net wealth.

Analysis: The questions referred were identical to those earlier answered by the court in another wealth-tax reference involving the same point. Following that decision, the court accepted that the assessee had an interest in the trust corpus on the relevant valuation date and that such interest formed part of the assessee's net wealth.

Conclusion: The questions were answered in the affirmative and against the assessee, with the result that the Revenue succeeded.

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