1971 (7) TMI 135

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....ppeals by special leave. The question for decision in these appeals is whether the goods in transit from England to India belonging to a non-resident assessee can be considered as wealth of the assessee during the relevant valuation dates. The relevant assessment years are 1957-58, 1958-59 and 1959-60. The assessee is admittedly a non-resident company. It is said that during the relevant valuat....

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....e provisions of the Act of all the assets, wherever located, belonging to the assessee on the valuation date, including assets required to be included in his net wealth as on that date under this Act, is in excess of the aggregate value of all the debts owed by the assessee on the valuation date other than . . . . " (The remaining portion is not relevant for our purposes). If these provisions h....

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....tioned earlier, the assessee is a non-resident company. Therefore, in computing its net wealth the restrictions placed by section 6 will have to be taken into consideration. Quite clearly, the High Seas cannot be considered as a part of India in the absence of anything in the Act making it a part of India. Therefore, prima facie, we must proceed on the basis that the goods with which we are con....