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Issues: (i) Whether, in valuing the assessee's shares, the amount representing advance income-tax paid by the company was required to be deducted from the provision for taxation under rule ID of the Wealth-tax Rules read with Explanation II(ii)(e); (ii) Whether the value of National Defence Certificates held by the assessee was exempt under section 5(1) read with section 5(1A) of the Wealth-tax Act, 1957.
Issue (i): Whether, in valuing the assessee's shares, the amount representing advance income-tax paid by the company was required to be deducted from the provision for taxation under rule ID of the Wealth-tax Rules read with Explanation II(ii)(e).
Analysis: The issue was covered by an earlier decision of the Court on the interpretation of rule ID and the relevant explanation governing valuation of shares.
Conclusion: The question was answered in the negative and against the assessee.
Issue (ii): Whether the value of National Defence Certificates held by the assessee was exempt under section 5(1) read with section 5(1A) of the Wealth-tax Act, 1957.
Analysis: The issue was covered by an earlier decision of the Court construing the exemption provisions under section 5.
Conclusion: The question was answered in the negative and against the assessee.
Final Conclusion: Both referred questions were answered in favour of the Revenue, leaving no relief to the assessee.
Ratio Decidendi: Where the controlling precedent has already interpreted the valuation and exemption provisions, the reference must be answered consistently with that binding interpretation.