1982 (5) TMI 36

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....verrides the provisions of section 24(6) of the Wealth-tax Act ? 2. Whether, on the facts and in the circumstances of the case, it is open to the revenue to rely on rule ID even though no specific argument was raised before the Tribunal ? 3. Whether on the facts and in the circumstances of the case, the Tribunal was justified in following the valuation as made by the valuers even though the valuation was not based on the statutory method of valuation provided under rule 1D? 4. Whether, the valuers to whom the valuation of shares was referred under section 24(6) of the Act, were, in law, bound to follow the method of valuation prescribed by rule ID of the Wealth-tax Rules? " For the assessment years 1965-66 and 1966-67 the assess....

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....essee, the Tribunal acting on the same, directed the WTO to adopt the value of the unquoted shares as per the valuation report. It may be noted that as a result, the value of the unquoted shares was taken at a somewhat increased rate than what had been adopted by the AAC and in the result the revenue's appeals were partly allowed. Still aggrieved the revenue has got the questions indicated above referred to this court. It would be seen that so far as questions Nos. 1, 2 and 4 are concerned, they do not arise out of the Tribunal's order and we have, therefore, to return them unanswered. So far as questions Nos. 3 and 4 (sic) are concerned, in view of the provision contained in s. 24(6) of the Act, the Tribunal acted rightly in deciding....