Wealth-tax valuation date follows the changed income-tax previous year, making assessment year 1957-58 unavailable on these facts.

For wealth-tax purposes, the valuation date under section 2(q) of the Wealth-tax Act, 1957 was linked to the last day of the previous year as defined under the income-tax law. Because the assessee's previous year had been validly changed, the relevant income-tax previous year ended on 30 June 1957, and that date also became the valuation date for wealth-tax. The corresponding wealth-tax assessment year was therefore 1958-59, not 1957-58. No wealth-tax assessment could accordingly be made for assessment year 1957-58 on that footing, and the position was held in favour of the assessee.

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Issues: Whether, for wealth-tax purposes, the valuation date for the assessment year 1957-58 had to be determined with reference to the assessee's changed previous year under the income-tax law, and consequently whether any wealth-tax assessment could be made for that assessment year.

Analysis: The definition of "valuation date" in section 2(q) of the Wealth-tax Act, 1957 links the valuation date to the last day of the previous year as defined in the income-tax law, if an assessment were to be made under that Act for the relevant year. Once the assessee's previous year had been validly changed, and the income-tax previous year would end on 30 June 1957, the corresponding valuation date for wealth-tax also had to be 30 June 1957. On that basis, the proper wealth-tax assessment year would be 1958-59 and not 1957-58.

Conclusion: No wealth-tax assessment could be made on the assessee for assessment year 1957-58 on the footing that the relevant valuation date was 30 June 1957; the answer was against the Revenue and in favour of the assessee.

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