Questions of law on reopening wealth-tax assessments and Valuation Cell reference power were found fit for court reference.

Questions of law were held to arise from the Tribunal's order on the justification for reopening wealth-tax assessments under section 17(1)(a) and on the Appellate Assistant Commissioner's jurisdiction under section 16A to direct a reference to the Valuation Cell. The High Court found that the proposed questions directly related to the Tribunal's findings on those issues and were proper for reference under section 27(3) of the Wealth-tax Act, 1957. The application was accordingly allowed, and the Tribunal was directed to state the case and refer the questions for the Court's opinion.

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Issues: Whether questions of law arose from the Tribunal's order on the justification for reopening the wealth-tax assessments and on the jurisdiction of the Appellate Assistant Commissioner to direct a reference to the Valuation Cell.

Analysis: The application was under section 27(3) of the Wealth-tax Act, 1957. The Court found that the two proposed questions related to the Tribunal's holdings on reopening under section 17(1)(a) and on the Appellate Assistant Commissioner's power under section 16A to direct reference to the Valuation Cell, and that such questions did arise from the Tribunal's order.

Outcome: The application was allowed and the Tribunal was directed to state the case and refer the questions to the Court for opinion.

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