COMMISSIONER OF WEALTH TAX Vs. SARA VARGHESE PVT

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 was assessed to wealth-tax. We are concerned with the assessment year 1973-74. Certain common questions of law were referred at the instance of the assesses herein for the very assessment year which were disposed of by this court in the decision in CWT v. Sara Varghese [1988] 170 ITR 436.

(3.) COUNSEL for the Revenue submitted that in the Himalaya Trading Co.'.s case [1987] 168 ITR 586 (Delhi) what was involved was only the method of valuation. Here the question referred to this court is regarding "the method and manner of valuation" of rubber estates. So, the manner of valuation involves the application of the principles of law. We are of the view that there is no substance in this plea. In Chambers Twentieth Century Dictionary, New Edition, 1983, at page 766, the word "manner" is explained thus ;