(1.) AT the instance of the CWT, Gujarat -III, Ahmedabad, two questions of law have been referred for our opinion under s. 27(1) of the W. T. Act, 1957, and they read as under :
(2.) SO far as question No. 1 is concerned both the learned advocates of the respective sides are agreed that it requires to be reframed to highlight the real question in controversy. We have accordingly, reframed the question as under :
(3.) ACCORDING to the WTO, this amount represented an asset of the assessee within the meaning of s. 2(e) of the W. Y. Act and was liable to be included as part of his assets as on the valuation date.