TMI Blog1992 (1) TMI 144X X X X Extracts X X X X X X X X Extracts X X X X ..... -2-1985 and the same was claimed to have been done by replacement cost method of valuation. According to the Assessing Officer, the insured value of the cars with the insurance company represented their reasonable market value. He, therefore, took their insured value at Rs. 23,60,000 as the assessable value and added the difference of Rs. 5,10,000 to the net wealth returned by the assessee. As regards the immovable property, the assessee returned the value as follows :-- (1) Mangalam (Dumas) Property Rs. 8,48,000 (2) Staff quarters in Surat Cotton Mills Compound Rs. 9,46,000 (3) Altamount Property Rs. 4,44,500 ------------------------- Rs. 22,38,500 ------------------------- The above value was worked out under rule 1BB based ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , and the resultant profits declared in the income-tax assessment. In this manner, the value of the flats was arrived at Rs. 1,52,00,000 and added to the net wealth of the assessee. The value of the servant quarter was estimated at Rs. 25,000. The assessee disputed the valuation as was done by the Assessing Officer. It was contended before the first appellate authority that the Dy. Commissioner was unjustified in rejecting the reports of the valuers and in working out the value of the different properties and the motorcars on estimate without any basis. It was also contended that he erred in rejecting the rule 1BB of the Wealth-tax Rules in connection with the value of the immovable properties. As regards the motor cars, it was urged that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estion of valuation to the Valuation Officer under section 16A of the Wealth tax Act, 1957. Drawing our attention to the provisions of section 23(3A)(b) and section 23(4)(b), it was argued that it was within the powers of the appellate authority in disposing of an appeal to seek such references or directing in seeking of such references to the Valuation Officer. 6. We have carefully perused the records and also considered the rival submissions. The determination of the valuation of any asset is entirely a matter of procedure and that can be done at any stage of the proceeding inasmuch as the appeal is a continuation of the original proceedings. In an appeal, the appellate authority can confirm the order of assessment, annul the same or re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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