TMI Blog1993 (7) TMI 15X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 27(3) of the Wealth-tax Act, 1957, seeking a direction to the Tribunal to state the case and refer the following question of law, which, according to the petitioner, arises in T.C.P. Nos. 833, 837 and 841 of 1991, relating to the assessment year 1982-83 in each case : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in upholding the order o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at all open to determine the value of the property on taking into consideration the event of sale that takes place nearly four years after the assessment year. As far as the Board's Circular No. 326, dated February 6, 1982, is concerned, the same was in force in the assessment year 1982-83, therefore, the Tribunal was justified in relying upon the same. We-are of the view that it is not at all ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e purpose of determining the valuation so that different methods are not followed by the Department for the purpose of determining the value of the property. In order to ensure uniformity in the manner and mode of determining the value of the property, the wealth-tax circular in question has been issued under section 10 of the Wealth-tax Act. In this regard, we may usefully refer to the decision o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Direct Taxes under section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act." However, it is contended that as the circular prescribed only the guidelines, the actual value of the property as in the assessment year 1982 83 ought to have been determined. With reference to this contention it is sufficien ..... X X X X Extracts X X X X X X X X Extracts X X X X
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