1985 (3) TMI 2

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..... he assessee interest due on accrual basis (though not realised) on the outstandings of the money-lending business, the accounts of the assessee being maintained on cash basis?" The respondent assessee was assessed to wealth-tax for the assessment years 1965-66, 1966-67 and 1967-68 (the respective valuation dates being March 31, 1965, March 31, 1966, and March 31, 1967), in the status of " Hindu undivided family ". In each of the assessments, the WTO included a sum of Rs. 1,50,000 estimated as the accrued interest on the assessee's money-lending investments. The assessee appealed to the AAC and urged that as it maintained its books of account in accordance with the cash system of accounting, the accrued interest on the money-lending investm .....

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..... ... " According to the scheme of the W.T. Act, the net wealth of an assessee has to be determined as it obtains on a particular date. That is the It valuation date ". Clause (q) of s. 2 defines the expression " valuation date " as follows: " (q) valuation date in relation to any year for which an assessment is to be made under this Act, means the last day of the previous year as defined in section 3 of the Income-tax Act, if an assessment were to be made under that Act for that year: Provided that (i) where in the case of an assessee there are different previous years under the Income-tax, Act for different sources of income, the valuation date for the purposes of this Act shall be the last day of the last of the previous years aforesaid .....

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..... That appears to be plain from the definition of "net wealth" which speaks of "the aggregate value ...... of all the assets" belonging to the assessee on the valuation date. All the assets of the assessee, barring those expressly excepted by the statute, are to be taken into account, and it is immaterial whether the assessee employs one system of accounting or another. There is clear indication that the assets to be considered are not circumscribed by any, consideration of the particular system of accounting adopted by the assessee. The assets are not confined to cash. Where the asset is an asset other than cash, its value if determined pursuant to sub-s. (1) of s. 7 as the estimated price, which, in the opinion of the WTO, the asset would .....

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