Partnership property and Schedule III valuation must be applied strictly in wealth-tax assessment, not direct asset attribution.

Where immovable property stands in the name of a partnership firm, the partner's wealth-tax exposure cannot be computed by directly attributing a proportion of the property's market value to the assessee; the correct approach is to value the assessee's interest in the firm under the prescribed rule. The document also states that valuation of the Saidapet property had to be made strictly in accordance with Schedule III of the wealth-tax valuation scheme, and not on an unadjusted basis. The additions were therefore not sustained in their assessed form and required fresh computation under the applicable statutory valuation method.

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Issues: (i) Whether the value of the property standing in the name of a partnership firm could be directly included in the assessee's net wealth instead of valuing the assessee's interest in the firm under the prescribed rule. (ii) Whether the valuation of the Saidapet property had to be made in accordance with the statutory valuation schedule.

Issue (i): Whether the value of the property standing in the name of a partnership firm could be directly included in the assessee's net wealth instead of valuing the assessee's interest in the firm under the prescribed rule.

Analysis: The property at Saidapet was accepted as standing in the name of the partnership firm, and the assessee's connection with it was only through her interest in the firm. In such a situation, the asset could not be brought to tax by directly taking a percentage of the property's value in the assessee's hands. The proper course was to determine the value of the assessee's interest in the firm in the manner prescribed for partnership interests.

Conclusion: The direct inclusion of 50% of the property's value in the assessee's net wealth was not sustained, and the matter required fresh determination under the prescribed method.

Issue (ii): Whether the valuation of the Saidapet property had to be made in accordance with the statutory valuation schedule.

Analysis: For wealth-tax purposes, the value of the property had to be determined under the statutory valuation mechanism in Schedule III. The assessment had proceeded without following that method, even though the assessee disputed the value adopted. The valuation therefore could not be retained as made and required reconsideration according to the prescribed schedule.

Conclusion: The valuation of the Saidapet property had to be redone under the statutory valuation provisions.

Final Conclusion: The additions relating to the two properties were not finally sustained in their assessed form, and the assessments were restored for fresh computation in accordance with the applicable wealth-tax valuation rules.

Ratio Decidendi: Where a property stands in the name of a partnership firm, the assessee's wealth-tax liability must be worked out by valuing the partner's interest in the firm under the prescribed rule, and any property valuation must be made strictly under the statutory valuation schedule.

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