HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Commissioner of Wealth-tax, Calcutta, now West Bengal II v. Tungabhadra Industries Ltd., Calcutta
Civil Appeals Nos. 1629 to 1631 of 1968
[1970] 1 SCR 789 ·
Wealth-tax Act, 1957: sections 7(1), 7(2)(a) and 27(6)
Sources & disclosures includedDownload original judgment / order
3-judge bench; unanimous judgment delivered by V. Ramaswami, J. · J. C. Shah, Acting C.J. · V. Ramaswami, J. · A. N. Grover, J.
Assessment years: 1957-58, 1958-59, 1959-60
01 · Facts of the case
For three years the officer valued the company's fixed assets at its own balance-sheet figures. The Tribunal substituted income-tax written-down values, and the High Court agreed, although the company had produced no material showing that those values represented actual value (SCR pp.789-792; PDF pp.1-4).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
Section 7(2)(a) permitted whole-business valuation by reference to a regularly maintained balance sheet, with adjustments needed to reach true value. An assessee could prove inflation or a better written-down value, but bore that evidentiary burden. After the Supreme Court rejected the Tribunal's legal approach, section 27(6) required a rehearing with both parties heard (SCR pp.792-795; PDF pp.4-7).
Source: Primary judgment: discussion
03 · Judicial decision
The legal question was answered for Revenue and the Tribunal was directed to dispose of the case after rehearing in conformity with the judgment; no costs were ordered (SCR pp.794-795; PDF pp.6-7).
Source: Primary judgment: decision
04 · Outcome / in whose favour
Revenue succeeded on valuation principle, but final fact application remained for the Tribunal on rehearing (SCR pp.793-795; PDF pp.5-7).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: distinguish accounting depreciation from evidence of actual asset value, and preserve the post-reference rehearing needed for fact application. Current valuation statutes and rules require independent analysis (based on SCR pp.793-795; PDF pp.5-7).
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
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Statutory scope
The case applies historical provisions of the Wealth-tax Act, 1957, since repealed for general wealth taxation; no current valuation regime is represented.
Later treatment
Source checked 2026-10-11. Later judicial treatment and current statutory applicability have not been comprehensively checked; no current-law or citator clearance is represented.
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