1986 (9) TMI 142

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....rding the value of the shares of M/s Udaipur Distillery Co. Ltd. Shri F.B Illavia and Smt. Homi Illavia had 125 and 220 shares respectively of Udaipur Distillery Co. Ltd., Whose shares are not quoted. The assessee valued the shares in accordance with the r. 1D and returned the value of nil. The WTO, on the other hand took the value of the shares at Rs. 2,25,000 and Rs. 3,96,000 on the basis that o....

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....ing reliance on Allahabad and Kerala High Courts as well as the two Tribunal decisions in WTO vs. Sheo Prasad Napany (1986) 25 TTJ (Cal) 297 : (1986) 16 ITD 166 (Cal) and WTO vs. Ritu Nanda (Mrs) (1985) 14 ITD 269 (Del) 3. We have considered the submission of the Department and also have taken note of the written submissions of the assessee. At the outset we may wish to observe that the submiss....

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....1), that is applying r. 1D or applying the provision of s. 7(2), can value the entire business as a whole and arrive at the value per share. When the WTO has to apply the provisions of s. 7(2), he has necessarily to follow the procedure that has been prescribed therein. He has to necessarily adopt the provisions that are contained in r. 2A to r. 2G. As already observed earlier the WTO does not car....