COMMISSIONER OF WEALTH-TAX Vs. AJAIPAT SINGHANIA

JUDGEMENT

(1.) In compliance with the directions of this court the Income-tax Appellate Tribunal, Allahabad Bench, Allahabad, hereafter "the Tribunal", has referred the following questions under Section 27(3) of the W.T. Act, hereafter "the Act", for the opinion of this court :

(2.) Whether, on the facts and in the circumstances of the case, it is open to the revenue to rely on Rule 1D 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?