Rule 1BB applicability made the Valuation Cell reference immaterial, so no referable question of law arose.

Rule 1BB was found applicable, and the Tribunal held that valuation had been correctly made on that basis. In view of that finding, alleged non-adherence to section 16A of the Wealth-tax Act did not affect the assessment, because a Valuation Cell reference became immaterial once the applicable valuation rule governed the computation. The proposed reference on section 16A therefore did not survive as an independent question and was treated as purely academic. No question of law was held to arise for reference on the issue raised.

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Issues: Whether a reference was called for on the question whether non-adherence to section 16A of the Wealth-tax Act, 1957, rendered the assessment order erroneous in law and prejudicial to the interests of the Revenue, where rule 1BB was held applicable.

Analysis: The Tribunal had recorded a categorical finding that rule 1BB was applicable and that the valuation had been correctly arrived at on that basis. In that situation, the question whether the Wealth-tax Officer had not acted under section 16A did not affect the outcome, because the applicability of rule 1BB made the Valuation Cell reference immaterial. Since the only question sought to be referred did not survive independently of the finding on rule 1BB, it was treated as purely academic.

Conclusion: No question of law arose for reference on the issue raised, and the petition was dismissed.

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