COMMISSIONER OF WEALTH TAX Vs. BEJOY KUMAR KARNANI

JUDGEMENT

(1.) The facts found and/or admitted in this Reference at the instance of the Commissioner of Wealth Tax, West Bengal III, are shortly as follows. Messers. Bejoy Kumar Karnani & Others, the assessee, a Hindu Undivided family, was assessed to wealth tax for the assessment years 1957-58 to 1961-62, the relevant valuation dates being 31st March of each of the years from 1957 to 1961.

(2.) At the relevant period the assessee held a number of shares in Karnani Properties Ltd. and Karnani Investment Pvt. Ltd. The Wealth Tax Officer following an order of the Tribunal in the Wealth Tax assessment to Bejoy Kumar Karnani (individual) estimated the value of these shares by the method known as "break up value" method. The shares of Karnani Properties Ltd. were accordingly valued at Rs.6/- per share for the assessment years 1957-58 and 1958-59 and at Rs.6.23, Rs. 6.18 and Rs. 6.18 respectively for the other assessment years i.e. 1959-60, 1960-61 and 1961-62.

(3.) The shares of Karnani Investment Pvt. Ltd. had to be valued for the assessment years 1959-60, 1960-61 and 1961-62. Again following the "break up value" method, the Wealth-tax Officer estimated the value of these shares at Rs.12/- per share for the assessment years 1959-60 and 1960-61 and at Rs.10.83 for the assessment years 1961-62.