Concealed income is not wealth-taxable as an asset unless it remains with the assessee on the valuation date.

Concealed income assessed under an income-tax settlement could not be included in total wealth unless it was shown to remain available with the assessee on the relevant valuation dates. The Tribunal's finding that the amount was not in the assessee's hands on those dates was decisive, and mere assessment in income-tax proceedings did not establish continued ownership or possession for wealth-tax purposes. An amount can be treated as an asset only if it exists with the assessee on the valuation date. The deletion from wealth was therefore upheld.

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Issues: Whether the amount of concealed income, assessed under a settlement, could be included in the assessee's total wealth for the relevant valuation dates under the Wealth-tax Act.

Analysis: The amount represented secreted income relating to earlier years, and the decisive inquiry was whether it remained available to the assessee as an asset on the valuation dates. The Tribunal recorded a categorical finding that the amount was not available with the assessee on those dates. The mere fact that the concealed income had been assessed in the assessee's hands under the income-tax settlement did not establish that the company retained the money or that it constituted property in its hands for wealth-tax purposes. An item can be treated as an asset only if it is available with the assessee on the relevant valuation date.

Conclusion: The amount was not includible in the assessee's total wealth, and the deletion made by the Tribunal was upheld.

Ratio Decidendi: For wealth-tax purposes, concealed income cannot be treated as an asset unless it is shown to have remained with the assessee on the relevant valuation date.

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