| Citation(s) |
|---|
| 2003 SLG 824 2003 SLD 824 2003 PTD 81 |
Income Tax Appellate Tribunal
W.T.As.993/LB and 992/LB of 1996, hearing DATE : 14-06-2001, decision dated: 27-06-2001
MUHAMMAD SHARIF CHAUDHRY, ACCOUNTANT MEMBER AND MUHAMMAD TAUQIR AFZAL MALIK, JUDICIAL MEMBER
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W.T.As.993/LB and 992/LB of 1996, hearing DATE : 14-06-2001, decision dated: 27-06-2001
MUHAMMAD SHARIF CHAUDHRY, ACCOUNTANT MEMBER AND MUHAMMAD TAUQIR AFZAL MALIK, JUDICIAL MEMBER
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Law: Wealth Tax Act, (XV of 1963)
Section: 23,7,46
Law: Wealth Tax Rules, 1963
Section: 8(2)(c)(i)(ii)
Wealth Tax Rules, 1963----R. 8(2)(c)(i)(ii)---Valuation of bonus shares---Method---Cost of bonus shares in general parlance may he zero but such shares have a definite value for the purpose of wealth tax---Law does not differentiate between ordinary shares and bonus shares---Method of valuation of ordinary shares as prescribed by R.8(2)(c)(i)(ii) of Wealth Tax Rules, 1963 is applicable to the valuation of bonus shares as well---Assessing Officer was directed by the Appellate Tribunal to obtain details of bonus shares and balance sheets of the companies in which such bonus shares were being held and then determined the value of bonus shares of the assessee strictly in accordance with R.8(2)(c)(i)(ii) of the Wealth Tax Rules, 1963. 1992 SCMR 1935 distinguished. ORDER MUHAMMAD SHARIF CHAUDHRY (ACCOUNTANT MEMBER). ---These two appeals have been filed by Revenue against appellate order, dated 16-6-1996 passed by Commissioner Income Tax/Wealth Tax Appeal Zone-I. Faisalabad under section 23 of the Wealth Tax Act for the years 1993-94 and 1994-95. It has been contended in the grounds of appeal that the value of assessee's ½ share in Goldberg property has wrongly been reduced by the Commissioner. It has been further contended that the value of bonus shares has wrongly been set aside with the directions to calculate the same on the ratio of case reported as 1992 SCMR 1935. It has also been contended in these grounds that the learned CIT has fallen in error to direct the WTO to accept the transfer of shares without transfer deed. Appellant's DR and assessee-respondent's AR have been heard. Available records have been perused. 2. The grounds of appeal have been prepared carelessly and in stereotyped manner. The issues raised in Grounds Nos. 2, 5 and 6 in the year 1993-94 and in Grounds Nos. 4 and 5 in the year 1994-95 are irrelevant as the same do not arise from the impugned appellate order of the Commissioner and even from the assessment orders of the Wealth Tax Officer. Hence these grounds are dismissed. This leaves only one issue in the field for our decision and that pertains to valuation of bonus shares held by the assessee in various companies. This issue is decided…
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