1984 (2) TMI 22

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....rence under section 27(1) of the Wealthtax Act, 1957 (for short called " the Act"), the following question of law has been referred for the opinion of the court: " Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the income of the Crown Flour Mills would not be included in the net wealth of the assessee company for the assessment year....

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....les P. Ltd. [1985] 153 ITR 201 (Delhi) ). In consideration of the facts and for the reasons recorded in our judgment of January 6, 1984 (which may be taken as part of this reference also), we answered the reference in favour of the Department and against the assessee. It was stated that in the case of immovable property of the value of Rs. 100 and above, its transfer can be effected only by means ....

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....ent withdrew that ground. In other words, in the income-tax assessment, that income remained excluded from the assessee's total income. If the income of Crown Flour Mills was adjusted against loss, then there would have been some profits available. In the wealth-tax appeal before the Tribunal, the question arose whether that excess income after adjustment of loss could be treated as the assesse....

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.... be separate and no rule of res judicata applies. It is on these facts that the question has been posed. Decisions arrived at in one assessment year are binding neither oil the assessee nor on the Revenue in respect of the, subsequent assessment years. The principle of estoppel has no applicability to successive assessments. The Revenue Authorities are not bound by any contention or admission or d....