COMMISSIONER OF WEALTH TAX Vs. RAJENDRA KUMAR JHUNJHUNWALA

JUDGEMENT

(1.) THE assessee is an individual. For the assessment years 1969-70 and 1970-71, the original assessment was completed on 26th October, 1970. THE officer reopened them on the ground that certain wealth had escaped assessment. THE assessee filed returns under protest. THE WTO passed a fresh assessment order on 9th March, 1973. In this he, inter alia, enhanced the value of shares of M.P. Sugar Mills owned by the assessee. He adopted the method prescribed by Rule 1D of the W.T. Rules in valuing these shares. THE WTO also included some assets which had been left out in the original assessment.

(2.) THE assessee went up in appeal. THE appeal was allowed in part. THE assessee then took the matter to the Tribunal.

(3.) AT the instance of the CWT, the Tribunal has referred the following two questions for our opinion: