C W T Vs. O P TANDON

JUDGEMENT

(1.) By this judgment we propose to answer the following question referred to this Court for its opinion by the revenue under Section 27(1) of the Wealth-tax Act (hereinafter referred to as the Act):-

(2.) The assessees are owners of properties bearing No. 177, 178 and 179,Rajpur Road Deharadun and No 23, Darya Ganj, Delhi. The Commissioner of Wealth-fax (A) directed the Income Tax Officer to value the said propertises in accordance with rule IBB of the Wealth-tax Rules. The revenue challenged the said direction on the ground that rule IBB which was enacted with effect from 1-4-1979, could not be applied to assessment year 1978-79. The Tribunal re)ected this contention holding that Rule IBB was of a procedural nature and, therefore, would apply to an assement which was pending at the time When the rule came into effect.

(3.) Before proceeding further it may be worthwhile to notice the relevant provisions of the Wealth-tax Act and the Rules as in force at the relevant time.