1982 (3) TMI 37

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....eference under s. 27(3) of the W.T. Act, 1957, a reference is sought of the following questions of law: " (a) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the adjustment in the balance-sheet as envisaged under Explanation II(i)(b) of the Wealth-tax Rules, 1957, is not limited to only a debit balance of the profit & loss account thereby exclu....

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....on the ground that it is a pure question of fact. The facts of the case are that the assessee was a shareholder of M/s. Punj Sons (P.) Ltd. owning shares of a face value of Rs. 75,000. The CWT passed an order under s. 25(2) holding that the WTO's order accepting the face value was erroneous and prejudicial to the interests of the Revenue. He valued the shares of M/s. Punj Sons (P.) Ltd., under ....

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....he value of the shares of M/s. Punj Sons (P.) Ltd., as being the same as the face value. The Tribunal accordingly held that there was no error in the WTO's order which could lead to its revision under s. 25(2) of the Act, and, nor was that order prejudicial or against the interests of the Revenue. These are the circumstances which have led to the application for reference. It was urged for the ....

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....es without taking into consideration the real value of the assets owned by M/s. Punj Sons (P.) Ltd. we will get an entirely artificial result. M/s. Punj Sons (P.) Ltd. invested as large sum as Rs. 17,85,600 in the shares of M/s. Pibco Ltd. These shares could be undervalued or they could go down in value. In the balance-sheet of M/s. Punj Sons (P.) Ltd. only the original purchase price would be men....