Law:

Section:

Section 24 of the Wealth-tax Act, 1957 - Appellate Tribunal - Appeals to - Assessment years 1972-73 to 1984-85 - Assessee was an individual belonging to royal family of Patiala - In course of wealth-tax proceedings, department had bifurcated residential land bounded by four walls of property into different segments and adopted different rates of land - On appeal, Tribunal considered facts of case and proceeded to hold in para 2.7 that value of residential house and land appurtenant to residential house might be valued as per provisions of section 7(4) - However, in para 2.9 of same order, Tribunal proceeded to hold that classification of land into different categories, area of land and valuation of land, was fair and reasonable - In view of apparent contradictions in Tribunal's order, assessee filed a miscellaneous application - Tribunal thus recalled its order for a limited purpose of determining valuation of land appurtenant to residential house in question - Subsequently, Tribunal concluded that there was no contradiction in findings recorded in paras 2.7 and 2.9 of its earlier order - Whether on facts, approach adopted by Tribunal in impugned order smacked review of earlier order - Held, yes - Whether, therefore, impugned order was to be set aside and, matter was to be remanded back with a direction to Tribunal to reconcile paragraphs 2.7 and 2.9 figuring in earlier order instead of writing a perfunctory order - Held, yes [Matter remanded] FACTS The assessee was an individual belonging to the royal family of Patiala. For the purpose of valuation of residential house of assessee, the department had bifurcated the residential land bounded by four walls of the property into different segments and adopted different rates of land. On appeal, the Tribunal considered the facts of the case and proceeded to hold in para 2.7 that the value of the residential house and the land appurtenant to the residential house might be valued as per the provisions of section 7(4). However, in para 2.9 of the same order, the Tribunal proceeded to hold that the classification of land into different categories, area of land and valuation of land, was fair and reasonable. The assessee…

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