1983 (8) TMI 108

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....TAT, Delhi Benches at New Delhi as a common consolidated ordering relation to asst. yrs. 1971-72 to 1975-76 in WT Appeal Nos. 1824 to 1828 (Del) of 1981 on appeals by the revenue and C.O. Nos. 3 to 7 (Del) of 1982 arising in above W.T.A. Nos. Preferred by the respondent-assessee: "Whether on the facts and in the circumstance of the case, the tribunal was justified in directing the wealth-tax Officer to revalue the house property at D.9, N.D.S.E., Part II New Delhi, in accordance with rule IBB of the wealth-tax Rules by holding that though it came in to existence w.e.f. 1st April, 1979 yet it had retrospective operation?" 2. We have heard at length the ld. authorised representatives of the parties. We have also given out due considerat....

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....Act deals with the topic, 'Value of assets how to be determined' and in the case standard Mills Company Ltd. vs. CWT, Bombay (1967) 63 ITR 470 at p. 476 (SC) their Lordships of the Hon'ble Supreme Court that s. 7 falls in chapter II which deals with the charged of WT and assets subject to such charges; it is intended to provide a machinery for the determination of value of assets. So s. 7 of the Act consequently r. IBB also is procedural and a procedure embraces in its fold all pending actions. If that was not so, then CBDT could dot have notified r. 1-D to be applicable to all pending assessments i.e. as having retrospective application. 7. In W.T.A. Nos. 205, 206 and 207, (Del) of 1977-78 wherein asst. yrs. 1973-74, 1974-75 and 1975-76....