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TMI BlogAmendment at a glance, Amendments to Income-tax Act , Amendments to Wealth-tax Act , Amendments to Gift-tax ActX X X X Extracts X X X X X X X X Extracts X X X X ..... d consequential changes 41 34AA Appearance by registered valuers 42 34AB Registration of valuers 43 34AC Restriction on practice as registered valuer 44 34AD Removal from register of names of valuers and restoration 45 35(1)(aa),(7A) Rectification of mistakes 39 36(2B) Prosecution of registered valuers 46 37(1), (3), Power to take evidence on oath, etc. 38 prov. 38A, 46(2)(ee) Powers of Valuation Officer/Manner in which and conditions subject to which they may exercise their powers 37, 47 46(2)(e) Jurisdiction of Valuation Officers/Areas within which they may exercise jurisdiction 34, 47 Gift-tax Act 15(6) Reference to Valuation Officers for ascertaining the fair market value of any property transferred by way of gift 48-51 23(6) to (8) Omission of provisions relating to arbitration of valuers - Appearance by registered valuer in certain matters 52 43A Appeal to Appellate Tribunal 53 Amendments to income-tax Act Acquisition of immovable properties in certain cases of transfer to counter evasion of tax TAXATION LAWS (AMENDMENT) ACT, 1972 Provisions in brief 5. The Amending Act has inserted a new Chapter XXA with a view to empowering the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th any machinery, plant, furniture, fittings or other things, such machinery, plant, etc., will also be regarded as immovable property and will be subject to acquisition along with such land or building. Transfers of leasehold rights in land, whether or not such rights are transferred along with machinery, plant, etc., will also be covered. [Sections 269A(e) and 269S] TAXATION LAWS (AMENDMENT) ACT, 1972 Transfers covered 7. For the purpose of Chapter XXA, "transfer", in relation to any immovable property, has been defined to mean transfer of such property by way of sale or exchange. Transfers by way of sale or exchange alone will, therefore, be covered by the new provisions. Other modes of transfer such as gifts, leases, etc., will be outside the purview of the provisions. [Section 269A(h)] TAXATION LAWS (AMENDMENT) ACT, 1972 Definitions of "apparent consideration" and "fair market value" 8. "Apparent consideration", in relation to any immovable property transferred by way of sale, would mean the consideration of sale as specified in the instrument of transfer registered under the Registration Act, 1908. Where the immovable property is transferred by way of exchange for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... him to refer the question to the Board for determination. [Sections 269A(b) and 269B and rule 48D of the Income-tax Rules] TAXATION LAWS (AMENDMENT) ACT, 1972 Special rules of evidence 10. Three special rules of evidence have been laid down in the Act which will govern all proceedings under the new Chapter XXA. These rules are as under : 1. The fact that the fair market value of any immovable property exceeds its apparent consideration by more than 25 per cent of such apparent consideration shall be conclusive proof of the fact that the consideration for such transfer as agreed to between the parties has not been truly stated in the instrument of transfer. In view of this rule, the parties concerned will be debarred from leading any evidence either at the stage of proceedings before the competent authority or any subsequent stage to prove that although there is a difference of more than 25 per cent between the apparent consideration and the fair market value, the consideration has in fact been truly stated in the instrument of transfer and no other consideration has actually passed. 2. Where the property has been transferred for an apparent consideration which is less than ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it may be noted that in a case where the fair market value of the property exceeds the apparent consideration by more than 25 per cent of such consideration, the parties will be debarred from leading any evidence to prove that the consideration had in fact been truly stated in the instrument of transfer [vide item (1) of this paragraph]. It, therefore, follows that the agreement to sell which has been registered under the Registration Act, 1908, will constitute relevant evidence only in cases where the difference between the fair market value and the apparent consideration does not exceed 25 per cent of such consideration. [Sections 269C(2) and 269F(9)] TAXATION LAWS (AMENDMENT) ACT, 1972 Conditions precedent to the initiation of acquisition proceedings 11. The competent authority will have the power to initiate proceedings for the acquisition of any immovable property which has been transferred by way of sale or exchange on or after 15-11-1972 only if the following three distinct conditions are fulfilled, namely :— a. he has reason to believe that the immovable property is of a fair market value exceeding Rs. 25,000 ; b. he has reason to believe that the fair market value ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot been truly stated with a view to facilitating tax evasion by the transferor or the transferee. Where, however, the parties concerned have been given an opportunity of being heard before commencement of acquisition proceedings, they will be entitled to lead evidence to rebut the aforesaid presumptions subject to the rules of evidence explained in the preceding sub-paragraph. In other words, it will be open to the parties to claim that the object of understating the consideration in the instrument of transfer was not facilitation of tax evasion by the transferor or the transferee and also, where the difference between the fair market value and the apparent consideration exceeds 15 per cent but does not exceed 25 per cent of the apparent consideration, to prove that the consideration had been truly stated in the instrument, and if the competent authority is satisfied with the evidence produced, he will not initiate proceedings for acquisition of property. In this connection, it may be mentioned that it is not incumbent on the competent authority to give the parties concerned an opportunity of being heard before initiating the proceedings. It has been specifically provided that bef ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... atisfied about the claim and has referred the matter to the Board for determination, the limitation will be six months from the end of the month in which the instrument of transfer of such property is registered or 30 days from the determination of the question by the Board, whichever period expires later. 3. Where acquisition proceedings cannot be initiated during any period of time by reason of any injunction or order of any court prohibiting the initiation of such proceedings or preventing the examination of documents or other materials required to be examined for the purpose of determining whether such proceedings should be initiated, the time of continuance of the injunction or order, the day on which it was issued or made and the day on which it was withdrawn, will be excluded in computing the period during which such proceedings may otherwise be initiated. Under section 269P, any person presenting a document which purports to transfer any immovable property to any other person will be required to furnish a statement in duplicate in respect of such transfer in the prescribed form along with the instrument of transfer. It has also been specifically provided that, notwithstan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 269P and rules 48E, 48G and 48H of the Income-tax Rules] TAXATION LAWS (AMENDMENT) ACT, 1972 Objections against acquisition and hearing by the competent authority 13. The transferor, the transferee, the person in occupation of the property if the transferee is not in occupation thereof and every other person on whom the competent authority has served a notice under section 269B(2) may prefer objections against acquisition of immovable property. Besides, any other person who is interested in the immovable property will have the right to prefer objections against the acquisition. The objections will have to be in writing. The limitation for making objections will ordinarily be 45 days from the date of publication of the notice of acquisition in the Official Gazette. However, in the case of transferor, the transferee, the person in occupation of the property and any other person on whom the competent authority has served a notice under section 269D(2), an alternative limitation period of 30 days from the date on which the notice of acquisition is served on him will be available if the period of 45 days referred to above expires earlier. For the removal of doubts, it has been s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her facilitating the reduction or evasion of the liability of the transferor to tax in respect of any income (including capital gains) arising from the transfer, or facilitating the concealment of any income or any moneys or other assets which have not been or which ought to be disclosed by the transferee for purposes of the Indian Income-tax Act, 1922, the Income-tax Act, 1961 or the Wealth-tax Act, 1957. The Commissioner of Income-tax whose approval is necessary for the purpose will be the Commissioner who may be specifically specified by the Board, by general or special order in writing, in this behalf. Where the competent authority is not satisfied that all the requirements as set out above are fulfilled, he will be required to pass an order in writing that the property will not be acquired under Chapter XXA. A copy of the order of acquisition or declaring that the property will not be acquired under Chapter XXA will be served on the transferor, the transferee and every other person who has preferred objections before the competent authority. It should be borne in mind that the three rules of evidence mentioned in paragraph 10 will apply in relation to the proceedings before ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... who is likely to be prejudicially affected by the proposed order has been given a reasonable opportunity of being heard. The Tribunal will serve a copy of any order passed in appeal or by way of rectification to the appellant as well as to the Commissioner. Since time is of the essence in acquisition proceedings, it has been specifically provided that the Appellate Tribunal shall dispose of every appeal as expeditiously as possible and make an endeavour to dispose of such appeal within 90 days from the date on which it is presented. The Appellate Tribunal's order will be final on questions of fact. [Section 269G and rule 48F of the Income-tax Rules] TAXATION LAWS (AMENDMENT) ACT, 1972 Appeal to High Court 15. An appeal from the Appellate Tribunal's order under section 269G will lie to the High Court on a question of law. The Commissioner as also a person aggrieved by the Appellate Tribunal's order will have the right to prefer an appeal to the High Court on any question of law. The appeal to the High Court will ordinarily be presented within 60 days of the date on which the appellant is served with the notice of the order appealed against. The High Court may, however, on a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... take possession of the immovable property and use such force for that purpose as may be necessary. For the purpose of taking possession of the property, the competent authority may requisition the services of any police officer to assist him. It has also been specifically provided that where a requisition is made by the competent authority, it shall be the duty of the police officer concerned to assist him in taking possession of the property. When the possession of the immovable property is taken by the competent authority, the property shall vest absolutely in the Central Government free from all encumbrances. It has been specifically provided that, notwithstanding that the property vests in the Central Government free from all encumbrances, the liability of the transferee or any other person will remain unaffected in respect of such encumbrances and such liability may be enforced against the transferee or such other person by a suit for damages. [Section 269-I] TAXATION LAWS (AMENDMENT) ACT, 1972 Quantum of compensation 17. The amount of compensation payable in respect of immovable property will ordinarily be in a sum equal to the consideration declared in the instrument ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sfied that there was sufficient cause for doing so, it may allow extension for such time as it may deem fit. The reference application should clearly state the compensation payable under section 269J(1) and the amount by which, in competent authority's estimate, such compensation should be reduced or increased. The court to whom the question of determining the reduction or increase in the compensation may be referred will ordinarily be the principal civil court of original jurisdiction. The Central Government has, however, been empowered under section 269A(c) to appoint any special judicial officer within any specified local limits to perform the functions of the court for purposes of Chapter XXA and after such appointments are made in respect of any area the principal civil court of original jurisdiction will cease to have jurisdiction in respect of cases under Chapter XXA in respect of that area. [Sections 269A(c) and 269J(1), (2) and (3)] TAXATION LAWS (AMENDMENT) ACT, 1972 Bar on imposition of penalties under the Income-tax Act and the Wealth-tax Act 18. Under the Land Acquisition Act, 1894, the Government is required to pay compensation in respect of properties acquired ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the person or persons entitled thereto as soon as may be after the property becomes vested in the Central Government. In a case where the compensation payable under section 269J(1) is to be reduced or increased on account of damage caused to the property or improvements made thereto and the matter has been referred to the court for determination, the amount of compensation as reduced or increased by the amount estimated by the competent authority will be payable as aforesaid. Where there is a dispute as to the apportionment of the compensation amongst persons entitled thereto or the persons entitled to compensation do not consent to receive it or if there is no person competent to alienate the immovable property or if there is any dispute in regard to title to receive the compensation, the Central Government will deposit the amount of compensation with the court and refer the matter for the decision of the court. If any person who is not lawfully entitled to receive the whole or any part of the compensation for the property acquired under Chapter XXA in fact receives such amount, he will be liable to pay the same to the person lawfully entitled thereto. In case of failure on the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Code of Civil Procedure when trying a suit for the purpose of (a) discovery and inspection, (b) enforcing the attendance of any person including any officer of a banking company and examining him on oath, (c) compelling the production of books of account and other documents, and (d) issuing commissions. He will also have the power to impose a fine up to Rs. 500 on a person who intentionally omits to attend or fails to produce books of account or documents in response to summons issued by him. Where the competent authority imposes a fine, he will send a copy of the order to the Income-tax Officer having jurisdiction over the persons concerned and the Income-tax Officer will then proceed to recover the amount in the manner provided in Chapter XVIID. The competent authority will also have the power to impound the books of account and other documents produced before him. [Section 269M] TAXATION LAWS (AMENDMENT) ACT, 1972 Rectification of mistakes 22. The competent authority will have the power to rectify a mistake apparent from the record at any time before the expiry of the limitation for presenting an appeal against the order sought to be rectified. Where the order is likely t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from such property or the property itself has been disclosed in any return of income or net wealth by the claimant or a notice in the prescribed form and containing the prescribed particulars in respect of the property has been given by the claimant to the Income-tax Officer. The notice will be in Form No. 53 prescribed under rule 122 of the Income-tax Rules, 1962. With a view to enabling the claimant to prove to the satisfaction of the court that the income from property or the property itself has been disclosed in the relevant return or, as the case may be, the prescribed notice has been given to the Income-tax Officer, the claimant will be entitled to obtain the relevant extracts from the return of income or wealth or a certified copy of the prescribed notice given by him. The application for obtaining the relevant extracts from the return or the copy of the prescribed notice will be made in Form No. 54 prescribed under rule 123 of the Income-tax Rules, 1962 and will be accompanied by a receipted treasury challan for Rs. 2 evidencing the payment of prescribed fees. Where such application is made, the Income-tax Officer concerned will furnish the relevant extracts or copy within ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of the cost of acquisition of an asset by its fair market value as on 1-1-1954, the fair market value as claimed by him may be higher than its actual fair market value. The provisions of section 55A(a) and (b)(i) will, therefore, not apply in such a case. It will, however, be open to the Income-tax Officer to make a reference to the Valuation Officer under section 55A(b)(ii). TAXATION LAWS (AMENDMENT) ACT, 1972 27. The Central Government have appointed a large number of Valuation Officers under section 12A of the Wealth-tax Act and these Valuation Officers will exercise their functions in relation to categories of assets for which they have been appointed. The jurisdiction of the Valuation Officers has been defined in rule 3A of the Wealth-tax Rules. The Valuation Officers will exercise the same jurisdiction for income-tax purposes also. The provisions of rule 3A of the Wealth-tax Rules have been explained in paragraph 34 of this circular. In cases covered by the provisions of clauses (a) and (b)(i) of section 55A, it will be incumbent on the Income-tax Officer to refer the valuation of the asset in question to the Valuation Officer and it will not be open to him to decide t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nstead the procedure now laid down in the Wealth-tax Act and applied referentially to the proceedings under the Income-tax Act will be followed by the Tribunal. As a transitional measure, however, an independent provision has been made in section 25(1) of the Amending Act specifically providing that while the cases where the appellant had sought a reference of the disputed value of an asset to the arbitration of two valuers prior to the omission of section 254(1A) or such reference had been made before that date will continue to be governed by the pre-existing provisions, no new reference for arbitration will be made after the omission of section 254(1A). TAXATION LAWS (AMENDMENT) ACT, 1972 30. A new section 287A has been inserted providing for appearance by registered valuers in certain matters. Under this section, any assessee who is entitled or required to attend before any income-tax authority or the Appellate Tribunal in connection with any proceeding relating to valuation of any asset may be represented by a registered valuer. The right to appear through a registered valuer does not, however, extend to cases where the assessee is required under section 131 to attend perso ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee's objections and other evidence. The valuation as made by the Valuation Officer will be binding on the Wealth-tax Officer who will make the assessment in conformity with the said valuation. Ancillary provisions have also been made to confer adequate powers on the Valuation Officers for enabling them to perform their duties including appearance before the appellate authorities. The existing provisions relating to arbitration by two valuers at the stage of appeal before the Appellate Tribunal has also been done away with. The various provisions in this behalf are detailed in the following paragraphs. TAXATION LAWS (AMENDMENT) ACT, 1972 Appointment of Valuation Officers, etc. 33. A new section 12A has been inserted in the Wealth-tax Act to enable the Central Government to appoint as many Valuation Officers as it thinks fit and the wealth-tax authorities to appoint as many overseers, surveyors and assessors as may be necessary to assist the Valuation Officers in the execution of their functions. The term "Valuation Officers" will, for purposes of the Wealth-tax Act, include Regional Valuation Officers, District Valuation Officers and Assistant Valuation Officers. [Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be available to the Wealth-tax Officer only after 31-12-1972, it has been provided that the rules defining the jurisdiction of Valuation Officers will come into force on 1-1-1973. [Section 46(2)(e) and rule 3A of the Wealth-tax Rules] TAXATION LAWS (AMENDMENT) ACT, 1972 Conditions for reference to the Valuation Officers 35. A new section 16A has been inserted enabling the Wealth-tax Officer to refer the valuation of any capital asset to the Valuation Officer with a view to ascertaining the market value of such asset. Under this provision, the Wealth-tax Officer may refer the valuation of any capital asset to a Valuation Officer in a case where the assessee has got the asset valued by a registered valuer and the value returned is in accordance with the estimate made by the registered valuer if he is of opinion that the value as estimated by the registered valuer is less than the fair market value of the asset. Other cases in which reference may be made to the Valuation Officer would be where the Wealth-tax Officer is of opinion that the fair market value of the asset exceeds the value of the asset as returned by more than 331/3 per cent of the value returned or by more than Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aluation Officer will consider the evidence produced by the assessee as also all other relevant material gathered by him and make an order under section 16A(5) estimating the value of the asset. One copy of this order will be sent to the Wealth-tax Officer and another to the assessee. The valuation made by the Valuation Officer will be binding on the Wealth-tax Officer and it will not be open to him to depart from the order of the Valuation Officer under section 16A(5) in so far as it relates to the valuation of the asset in question. Since an appeal against the assessment order made by the Wealth-tax Officer will lie to the Appellate Assistant Commissioner, a copy of the Valuation Officer's order under section 16A(5) should invariably be appended to the assessment order and made integral part of the same. [Section 16A(2) to (6)] TAXATION LAWS (AMENDMENT) ACT, 1972 Power of inspection 37. A new section 38A has been inserted in order to confer certain powers on the Valuation Officer and any overseer, surveyor or assessor authorised by him in this behalf. A Valuation Officer or an overseer, surveyor or assessor authorised by him by an order in writing in this behalf will be able ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ice will not be necessary. Where a person who is required to afford the requisite facilities to the Valuation Officer or any authorised overseer, surveyor or assessor, refuses or evades to afford the facility, the Valuation Officer will have all the powers under sub-sections (1) and (2) of section 37 of the Wealth-tax Act for enforcing compliance with the requirements made. In other words, he will have the powers of discovery and inspection, enforcing attendance of persons, compelling production of books of account and other documents and issuing commissions for the purpose. He will also have the power to levy fine under section 37(2) on persons who fail to comply with summons issued for giving evidence or production of accounts, etc. The provisions of section 38A have been brought into force with effect from 15-11-1972 with a view to enabling the Valuation Officer to exercise his powers of entry and inspection in relation to immovable property in respect of which a reference is made to him by the competent authority for the purposes of Chapter XXA of the Income-tax Act. Similar powers under the Wealth-tax Act will be available after the provisions of section 16A of that Act rela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [Section 35] TAXATION LAWS (AMENDMENT) ACT, 1972 Appeal to the Appellate Assistant Commissioner 40. Section 11 of the Amending Act has made certain amendments in section 23 relating to appeals to the Appellate Assistant Commissioner from the orders of the Wealth-tax Officer. An appeal will lie to the Appellate Assistant Commissioner against an order of rectification of the Valuation Officer under section 35 having the effect of enhancing the valuation of any asset or refusing to allow the claim made by the assessee under that section or an order of the Valuation Officer imposing a fine under section 37(2) on any person for omitting to attend or produce books of account, etc. Further, where the valuation of any asset is objected to in an appeal against the assessment made by the Wealth-tax Officer, the Appellate Assistant Commissioner shall give a hearing to the Valuation Officer if the value of the asset which is questioned had been estimated by the Valuation Officer. In a case where the asset had been valued by the Wealth-tax Officer on his own without making any reference to the Valuation Officer, it will be open to the Wealth-tax Officer to request the Appellate Assistant C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aforesaid sub-sections. [Section 25(2) of the Amending Act and sections 24 and 26 of the Wealth-tax Act] TAXATION LAWS (AMENDMENT) ACT, 1972 Registered valuers 42. Section 14 of the Amending Act has inserted a new Chapter VIIB relating to registered valuers. Under new section 34AA, any assessee who is entitled or required to attend before any wealth-tax authority or the Appellate Tribunal in connection with any proceeding relating to the valuation of any asset may be represented by a registered valuer. This right to appear through a registered valuer does not, however, extend to cases where the assessee is required under the Act to attend personally. TAXATION LAWS (AMENDMENT) ACT, 1972 43. Section 34AB sets forth the procedure for registration of valuers. The Central Board of Direct Taxes will be required to maintain a register to be called the Register of Valuers in which the names and addresses of persons registered as valuers will be entered. Any person who possesses the requisite qualifications prescribed in this behalf in rule 8A of the Wealth-tax Rules may apply to the Board for being registered as a valuer. Different qualifications have been prescribed in rule 8A of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eferred to in (a), (b) and (c) above. An application for registration as a valuer must be accompanied by a fee of Rs. 250. [The Central Board of Direct Taxes will not accept cheques, drafts, hundis or other negotiable instruments in payment of the prescribed fee. The fee should be credited in the Treasury or a branch of the State Bank of India or a branch of the Reserve Bank of India after obtaining a challan from the Wealth-tax Officer and the receipted challan should be enclosed along with the application.] It should be noted that valuer of stocks, shares, debentures, securities, shares in partnership firms and of business assets including goodwill will not be entitled to value assets which are in the nature of immovable property, agricultural lands, forests, mines and quarries, machinery and plant, jewellery, works of art, life interest, reversions, or interest in expectancy for which separate categories of valuers have been registered. Rule 8C of the Wealth-tax Rules lays down that the fees to be charged by a registered valuer for valuation of any asset will not exceed the amount calculated at the following rates namely : on the first Rs. 50,000 of the asset as valued - ½% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is satisfied after giving the person concerned a reasonable opportunity of being heard and after such further enquiry, if any, as it deems fit to make that— a. his name has been entered in the Register by error or on account of misrepresentation or suppression of a material fact; or b. he has been convicted of any offence and sentenced to a term of imprisonment or has been found guilty of misconduct in his professional capacity which, in the opinion of the Board, renders him unfit to be kept on the Register. The Board has also been empowered to restore to the Register the name of any person so removed on an application made by the person concerned if it is satisfied that there is sufficient cause to do so. [Sections 34AA, 34AB, 34AC and 34AD and rules 8A, 8B, 8C and 8D of the Wealth-tax Rules] TAXATION LAWS (AMENDMENT) ACT, 1972 Prosecution of registered valuers 46. Section 16 of the Amending Act has amended section 36 relating to prosecutions. A registered valuer who makes a statement in a verification in a report of valuation under section 34AB which is false and which he either knows or believes to be false or does not believe to be true shall be punishable with impriso ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diction of the Valuation Officers has been defined in rule 3A of the Wealth-tax Rules. The Valuation Officers will exercise the same jurisdiction for gift-tax purposes also. The provisions of rule 3A of the Wealth-tax Rules have been explained in paragraph 34 of this circular. In cases covered by the provisions of clauses (a) and (b)(i) of sub-section (6) of section 15 of the Gift-tax Act, it will be incumbent on the Gift-tax Officer to refer the valuation of the property in question to the Valuation Officer and it will not be open to him to decide the question of valuation on his own. TAXATION LAWS (AMENDMENT) ACT, 1972 50. The Amending Act has made several provisions in the Wealth-tax Act relating to references to the Valuation Officer by the Wealth-tax Officer and appearance by registered valuers. These provisions have been referentially applied to proceedings under the Gift-tax Act relating to valuation of properties transferred by way of gift. The following provisions of the Wealth-tax Act applicable in relation to reference made by the Wealth-tax Officer under section 16A(1) of that Act will apply, mutatis mutandis, to references made by the Gift-tax Officer under sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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