COMMISSIONER OF WEALTH TAX Vs. XAVIER K G

JUDGEMENT

(1.) AT the instance of the Revenue, the Income-tax Appellate Tribunal has referred the following question of law for the decision of this court:

(2.) THE respondent is an assessee to wealth-tax. He is a partner of Geo Sea Foods. We are concerned with the wealth-tax assessment of the respondent/assessee for the year 1974-75. THE relevant valuation date is March 31, 1974. For the same assessment year (1974-75), the Income-tax Officer has included the following four items in the total income of the assessee :

(3.) ON hearing the rival pleas, we are of the view that the plea of the Revenue should prevail. In Anantharam Veerasinghaiah and Co.'s case [1980] 123 ITR 457, at page 462, the Supreme Court dealt with "intangible" assets as follows :