Intangible additions may count as wealth-tax assets when available on the relevant valuation dates.

Intangible additions made in income-tax proceedings were treated as part of the assessee's real income and, for wealth-tax purposes, could form part of net wealth under section 2(e) and section 2(m) of the Wealth-tax Act, 1957, unless it was shown that such additions were not available with the assessee on the relevant valuation dates. Applying its earlier view, the court accepted the Revenue's position and concluded that the additions were assessable as assets in the absence of a finding of non-availability on those dates.

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Issues: Whether intangible additions made in income-tax proceedings could be treated as assets of the assessee for wealth-tax purposes under section 2(e) and section 2(m) of the Wealth-tax Act, 1957.

Analysis: The issue was governed by the court's earlier view that intangible additions represent part of the assessee's real income and may be included in net wealth on the relevant valuation dates, unless it is found that such additions were not available with the assessee on those dates. Applying that principle, the court accepted the Revenue's position and answered the reference consistently with the earlier decision.

Conclusion: The intangible additions made in income-tax proceedings could be treated as the assessee's assets for wealth-tax assessment under section 2(e) and section 2(m) of the Wealth-tax Act, 1957, in the absence of a finding that they were unavailable on the relevant valuation dates.

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