2002 (6) TMI 24

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....provisions of rule 1B of the Wealth- tax Rules and not by actuarial method of valuation representing the market value of the interest in accordance with the provisions of section 7 of the Wealth-tax Act? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in not accepting the value of life interest in Suhasbhai Vadilal Family Trust No. 1 and Suhasbhai Vadilal Family Trust No. 2 as determined by the actuary?" The applicant-assessee is assessed to wealth-tax as an individual. The relevant valuation date was March 31, 1978. The applicant had a life interest in Suhasbhai Vadilal Family Trust No. 1 and Suhasbhai Vadilal Family Trust No. 2. The value of life interest was declared by the applicant on the....

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.... and in the context of the other rules regarding valuation, the apex court has already held that the rules of valuation were introduced in order to impart a uniformity in valuation and to avoid vagaries and disparities resulting from application of different methods of valuation in different cases where the nature of the property is similar. Learned counsel relied on the decisions of the apex court in Bharat Hari Singhania v. CWT [1994] 207 ITR 1 and CWT v. Sharvan Kumar Swarup and Sons [1994] 210 ITR 886. Having heard learned counsel for the parties, we are of the view that there is considerable substance in the submissions made by Mr. Tanvish Bhatt on behalf of the Revenue. In Bharat Hari Singhania's case [1994] 207 ITR 1, the Supreme ....