{"id":120475,"date":"1965-02-17T00:00:00","date_gmt":"1965-02-16T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/pramod-kumar-jain-vs-commissioner-of-wealth-tax-on-17-february-1965"},"modified":"2018-01-28T07:01:16","modified_gmt":"2018-01-28T01:31:16","slug":"pramod-kumar-jain-vs-commissioner-of-wealth-tax-on-17-february-1965","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/pramod-kumar-jain-vs-commissioner-of-wealth-tax-on-17-february-1965","title":{"rendered":"Pramod Kumar Jain vs Commissioner Of Wealth-Tax, … on 17 February, 1965"},"content":{"rendered":"
Bombay High Court<\/div>\n
Pramod Kumar Jain vs Commissioner Of Wealth-Tax, … on 17 February, 1965<\/div>\n
Equivalent citations: AIR 1966 Bom 166, (1965) 67 BOMLR 659, ILR 1965 Bom 1054<\/div>\n
Author: Desai<\/div>\n
Bench: Tambe, Desai<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
 Desai, J. <\/p>\n
 (1) The  question,  which has been referred to us under S. 72 (1)  of the Wealth Tax Act, 1957 at the  instances  of the assess, is as follows.\n<\/p>\n
   “Weather for the assessment, year  1959 – 60 the net wealth for the  asses has rightly  been charged at the rate of  1 per cent.”\n<\/p>\n
  (2) The relevant Valuation  date for the  computation of the net wealth  of the assessee for the assessment years  1959 – 60  was the 31st  March 1959. By S. 21 of the Finance  Act of 1959   the Wealth  Tax Act was amended altering  the rate of the  wealth  tax in the schedule of the Act.  The amendment as made  effective  from the  1st of April 1959.  The result  oft his amendment was  that the rate  of the rate  wealth tax. Which was  applicable to the   net wealth  of the assesee was  increased from 1\/2  per cent to 1 per cent.  That  assessee’ contention  was  that the amendment  of the wealth  Tax Act  in  creasing the rate o the tax come into  operationally form  the 1st of the April 1959. The rate  of tax on the  date with  reference  to the which his  net wealth  was to be  reference to which   computed  i.e. 31st  the March 1959, was only  1\/2 per  cent.  According  to the  which is applicable to the rate of tax which exists in the schedule  of the  wealth Tax Act  on the relevant  valuation  of the date for the  computation sent case the  rate that the applicable  was the rate. Which existed  in the Schedule   of 31st March  1959 since  on that  date  the rate of only 1\/2 per cent, that is that rate which must be  applied  to the net wealth  of the assesee as computed on the relevant  valuation of the date viz.,  31st  March  1959.\n<\/p>\n
  (3) In order to appreciate  this contention of the assessee ,we must consider  S. 3 of the Wealth Tax act,  which is the Charging  section. That section reads as follows:\n<\/p>\n
   “Subject  to the other  provisions  contained in this Act,  there shall be  charged for every  financial  year commencing  on the and from  that first day of April 1957, a tax  (hereinafter referred  to as wealth  tax) in  respect  of the net wealth  of the corresponding  valuation date of the every,  individual  Hindu undivided  family and company at the rate oft  specified in the schedule”.\n<\/p>\n
  Assessment  year”  under the Act  means the year for which tax is  chargeable under S. 3 and therefore  mean every  financial  year commencing on the and  from the 1st  of April  1957. “Net  wealth”  as defined  in S. 2 means  the amount y which the  aggregate  value computed  in accordance’s  with the  provisions the Act  of all the assets,  wherever located,  belonging to the  assessee on the valuation  date including assets required  to the included  in this net  wealth  as on  that date  under this Act,  is in  excess  of the  aggregate  value  of the all the  debts  owed by  the assessee  on the valuation  of date of the  than certain specified  kinds  of debts of and the amounts of certain taxes, penalties and interest.  “Valuation date”  in  relation to any years  for which an assessment is to be made  under this Act  means the last day of the  provisos year as defined  in C1 [11] of S. 2  of the Income – tax Act  it an  assessment  were under to be  made  the act for that years  and if there  were different  previous  years under the  income tax  act for  different  sources  of income, the last day  of the last of the such previous  years. Under  S. 3 with the which we are  concerned  and which is the charged section wealth  tax in  charred for every  financial yea.  It is a tax  on the  net wealth as  computed for the financial  year and the  rate of tax is the  which is to be found in the schedule  of the Act applicable to the computed quantum of the net wealth.  The dispute in the is case centers on the question  as to what rate is the  applied  to the net wealth in the present case.  It is the rate,  which  existed in the schedule  to the act on the date, which is the date for the  computation of the  net wealth  of the assessee or is it the  rate which  is applicable  to the financial  year,  for which  the tax is to be levied on the net wealth?\n<\/p>\n
  (4) It is argued  on behalf  of the Department  that the tax being  for the financial year the rate of the tax is that which  is applicable  to the  financial  year in question  and it is that the which must be applied to the net wealth.  That the net wealth is computed  with the references to the date which  is anterior to the commencement  to the financial year for which the wealth  tax is finance levied,  does not  for  mean that the  tax is attached  by the net – wealth  at any point of the time earlier  then the  commencement of  the financial years for which  the tax is levied.  The valuation of the specified in the Act is only for the purpose  of fixing the  point of time with the reference  to which the net wealth  which will attract  the tax  and will be  determined,  of  but is not  the date for the  attraction of the  tax.  Tax is only  attracted at commencement of the financial years  and at no point  of time earlier  in then that The tax is again  attached  or charged in  accordance with the  provisions  of the Act,  which exist at the point  of time of the  but the tax Net – wealth  no doubt,  it computed  with reference to an  anterior point  of time but the computation takes places according to the provisions  of the act as they  exist in the  relevant  financial year  net wealth the deductions and exclusions,  which will  be  permissible  under the act  are all according  to the act all the according  to the act as it the  that exists  and  relevant financial year. It is argued   that S. 3 states that the tax is  other  provisions  contained in this Act. The provisions  of the Act,  which have to be  borne  in mind and  considered  for the purposes  of charging  the  tax are the  provisions  of the year. The rates  specified  in the schedule  which the  rates  which  respected  the in given  financial  years in which the tax its charged.\n<\/p>\n
  (5)  In Our  opinion,  the submission  which has been  advanced  on behalf  of the Department  with regard to the interpretation of S. 3 of the wealth  Tax Act  appears to be correct. Although  the net wealth  is required to be ascertained  as on a date of the  anterior to the  commencement oft financial year for which  the tax is  charge the  said that the  is only for the purpose  of  fixing  the point to time  with reference  of which  the  quantum of wealth  which will bear the tax is to be  ascertained. What  that quantum will be will have  to determined  according to the provisions  contained  in Act at the time when the determination  of quantum would  become necessary  for the assessment  of the tax  liability for the  financial years in question.  The provisions of the act which will determine the quantum of the net wealth will not be  wealth his to be computed  by the provisions which are applicable  during  the period  of assessment of the which the tax is levied.  Under  S. 3 the  unit of the period for the  levied  is financial years. The valuation  date which  is the date with reference  to which the net wealth  is to be computed,  is the last day of the previous  year. In the present  case the valuation  is to be computed is the  was 31st March  1959, but it impossible according to the  year chosen  assess that it could  be a date  much anterior  to the commencement  of the  financial  year for which  the tax is levied.  For  instances  where the  after  the  calendar year is the  account in year of the assessee. It would be  the  31st the December or where the assessee has any the valuation of  date may be  some item in October  or November  of the  earlier year.  Net wealth  for the purposes  the wealth  Tax act  will not bout have to be determined with referenced to these  various  dates in the case  finance year in which   the tax liability of  attached by the net  wealth  on Nor is the tax  attracted by the net wealth  on those  particular  dates. If the law changes  during  the internal  between  the valuation  dates and the  which   charged the tax that will  be attached will be in the  accordance’s the  with the provisions  of the Wealth  Tax Act  is the stands  at the time oft attrition of the  act  not as it was  on the valuation  date.\n<\/p>\n
  (6) In our opinion,  therefore,  in the  present case the rate that was  applicable  to the net wealth  oft assesse for the assessment  found in the  schedule  of the act  as it stood  on the 1st  of April  1959.\n<\/p>\n
  (7) Mr. Kolah,  learned  counsel for the  assessee  has pressed  upon us a  different construction of S. 3 of the Wealth  Tax Act. He has argued  that on the  languages  of S. 3,  the tax is charged  on the net wealth  at the rate of the rates  which are  specified in the  schedule  on the corresponding valuation  of date with  reference to which  the net-wealth  is computed.  The learned counsel  has argued  that the   scheme  of the wealth Tax Act  is different  fro m the Income – tax act.  Under the income – tax  Act the charging section only brings  in the charge ability  of the income to tax.  The charge is actually  imposed  by the finance act, which is   required  to the passed for the purpose of the imposition of  tax. Under the income -tax  act therefore although  the income  of the previous  year assailable to charge,  the actual  charging of imposition  of the tax is only  when the rates are  declared by the Finance  Act. Even  after the introduction  of S. 67B  oft India  income-Tax  whereby the absences   oft Finance Act  being passed  the rates  underrate  earlier  Finance Act  are made prevail the  position is not  under altered  because  to the application of the rate under the  earlier finance act  are made  prevail the position is not  altered because act  application  of the rate under the  act also does not  come in unless  the Finance  act is not passed on or before  the 1st of April  of year in the question and  consequently  there is no charge  in income –  tax even according  to the rates  of earlier  finance  act until to the  1st of April of the year which is  necessarily  after the last  income liable  to income – tax  eared.  That  is however not so under  the wealth  Tax Act. The  entire machinery  has been provided  in the  act itself. The rate  of at which  the tax is to  be brought  in by another act  as inter case of Income- tax  and but the y  in wealth  Tax Act  itself.  The entire  machinery  not only for bringing  in the charge  ability  of net wealth  to wealth  tax but also  for  the charring  of the tax is contained  in the Act  itself.\n<\/p>\n
   (8) Mr.  Kolah has argued  that this  difference  in the schemes of two Act has got to borne in mind in  interpreting the charging section  in the  Act before  us. According to him the  charging section has provided  that a tax  will be  charged  on the net wealth  that a tax will be charged on the net  corresponding valuation  date at the rate   to be found   in the schedule of the  Act  although  this taxation  is for every  financial year the tax is  charged  on the net  wealth  on the date which is the valuation date  for the net wealth.  The charging  being on the date of the valuation date the rate of the at which the charge  will be make must obviously to be the rate which  exists  on the date  of charging  viz., on the date of the valuation  His argument  is that such  a construction  must be  put on S. 3 because  of the expression  “on  the  corresponding  valuation date”  following the words “in respect of the net – wealth”  occurring in the said section Mr.  Kolah  argues that if the  charging was not  intended  date itself the those  words viz.,  “on the corresponding  valuation date” were  thoroughly and not required to be used at all.  The argument of the  learned counsel is that  net wealth  as defined learned counsel act means net wealth  as computed on the valuation  date and “Valuation  date”  is an expression  which can only  be understood  with the reference  to the year  of assessment  for which   the tax is levied  being the  last day  of the previous  year relevant  to the assessment   year. The use of the words “net  wealth”  therefore was sufficient to mean net  wealth  as computed on the corresponding  valuation the date” shall be charged as occurring in  the section and the meaning of the section,  therefore it  that the tax,  which is charged  under the valuation of the  date on the net wealth  as computed with references  to that  the date and at the  rate of rates as  existed  in  the schedule on the date  of charging.  Now, the words “on the corresponding  valuation dated appear  to create some difficulty but we do  not think that the  they have even used for the  purpose and object  as contended  by Mr.  Kolah. The  tax charged  by the section  is a tax  for every financial year commencing from the 1st day of April  1957.  The subject  matter of the  tax is the net wealth  as it exists at certain specific  point  to time  referred to as the valuation  date with  reference  to each finical  year  for which  the tax is  charged.  The subject – matter  of tax there’re the  which is expressed by the  expression  “net wealth”  is not a fixed or  constants  amount which is determined  once of all years of  taxation.  What is intend to be  taxed in each  financial  year is the end  for  wealth  for the year that is  the net wealth  is  computed  on the valuation  of date in relation  to that year. The charging  section, which is  permanent provision providing for the charging of the tax for all financial years for which  the net wealth Tax Act will be  on the statute  book has  brought  out then intention  by specifying  that the in each financial year  will be  charged  in respect of net wealth on the corresponding valuation date.  In our opinion it is for this  reason  that the words  “on the corresponding valuation have been  incorporated  in the section after the words “in  respect  of the net wealth”  we do  not think  that it is intended  by S. 3 of the  wealth Tax  Act that the wealth tax  for any financial  year should be actually charged at  any point of the time  anterior to the commencement of the said  year. If we were to the accept the interpretation  which is  canvassed before on  behalf of assess it  may lad to some curious result.  Thus, for  instance for the  first years  1957-58 on wealth of the asesee.  The valuation  date for the first years  would in the  case of every  asessee be  anterior to the 1st of April 1957 when the Act  come into the force  If Mr. Kolah’s  interpretation  of S. 3 in accepted that the tax  is actually  charged  on the valuation of  tax  acutely charred schedule  as applicable on that date there will been  schedule  charge to the  wealth tax act.  Wealth Tax  act along  with its schedule  and the rates  specified therein came into  operation  only on the  1st  April 1957.  Although therefore the charging  section of the wealth  Tax Act  says that  the tax will be  charged  for the financial year  commencing  from the 1st of April, 1957, there will  actually  be no  wealth that  from a certain  financial years onwards the wealth tax should be  abolished  either  completely or partially or that is should be amended  as increase the burden  or grant itself relief against the  increase the  will not take effect in spite of the said intention of the legislation for at least a period  of one year, because of if the interpretation,  which Mr.  Kolah seeks to put upon  the section is accepted  on the valuation  date itself  the net wealth  as gets computed  under  the provisions  of the Act  is as it  existed  at that time  of and the tax at the rate  of a applicable  on that the date  the  also  gets attached  to it.  We do net think that the meaning which Mr. Kolah  wants to give to the  language of S. 3 of the meaning  which was intended by the  legislature.\n<\/p>\n
  (9) Mr. Kolah  has argued  that curious and anomalous result  will follow from the proper  construction of the section  is no reason  for the court to  abandon such a construction. It may  be true  that where  the provision of  the statute issue clear  leave  no doubt,  as to what its meaning  and construction is the  mere  circumstances  and construction is the mere section its proper  meaning  and effect  is likely  to lead to certain anomalous or curious results  would not be a considerate for the courts  to reject  would not be consideration.  The defect in such he cases will have  to be cured by the legislature. That is now  ever so where the position issue that the meaning  of what the legislature is  has said is clear and  unambiguous  and the section leads only to one  construction and to  no other.  That however,  is not the position  in the present  case.  In the first  place the construction  which Mr. Kolah  has sought  to put on  S. 3 does not  appear to be the true  and proper construction even on the language employed in the section Assuming  the construction  such as he  has put on the  section  is one possible constructions,  there asset opinion,  a mush betters  and a more  reasonable construction, which the  languages  of S. 3 is the  quite capable of veiling to. There can  be no  doubt whatsoever of that , when  there’re two  possible constructions  even  when   both are  equally  possible  constructs that even when both the are  equally possible  constrictions  even when  both are  equally possible though  such is not  the position  in the present though  such his not  present case.  If one of the  construction leads  in curious  and anomalous results  and tends to defeat what the  legislature has  intended  while the other  produces  on such results  and is quite  consistent  with the scheme  of  the Act  of and the  manifest  intention of the legislature,  it is  the latter  one that will have to be preferred.\n<\/p>\n
  (10) In Order  to emphasize his arguments that the scheme  under the Wealth Tax Act is different  from the schedule  under  the Indian Income – Tax  schemes   has got to borne in mind in interpreting  the charging  section in the wealth Tax  act, Mr.  Kolah has invited  out attention  to commissioners Wealth Tax, Bombay  v. Standard  Mills co. Ltd.,  1963-50 ITR  267  [Bom]  and Chatturam  Horiram  Limited v. Commissioner of the Income – tax, B & O,  Where  is the scheme of the Income  – Tax  act with  reference to the charge ability to tax under the act and the imposition of  the tax of the  attraction of the   tax liability  have been considered. We do not  wish to makes  any detailed   references of the  with Mr. Kolah  that there is  undoubtedly  a differences in the  scheme of two  Acts.  The charging section of the wealth Tax Act, however,  has got to be  interpreted  on its own  languages and in view  of the scheme  under the Wealth and Tax Act  and in giving  out construction  had interpretation in to said  section we  have property  borne in mind the difference in the scheme of the two Act,  to which  Mr. Kolah  has invited out attention.\n<\/p>\n
  (11)  In the result  therefore our answer  to the question which has been  referred to us is in the  affirmative. The assessees  will pay the  costs of the  department.\n<\/p>\n
 (12) Answer in the affirmative.<\/p>\n","protected":false},"excerpt":{"rendered":"
Bombay High Court Pramod Kumar Jain vs Commissioner Of Wealth-Tax, … on 17 February, 1965 Equivalent citations: AIR 1966 Bom 166, (1965) 67 BOMLR 659, ILR 1965 Bom 1054 Author: Desai Bench: Tambe, Desai JUDGMENT Desai, J. (1) The question, which has been referred to us under S. 72 (1) of the Wealth Tax Act, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[11,8],"tags":[],"class_list":["post-120475","post","type-post","status-publish","format-standard","hentry","category-bombay-high-court","category-high-court"],"yoast_head":"\nPramod Kumar Jain vs Commissioner Of Wealth-Tax, ... on 17 February, 1965 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/pramod-kumar-jain-vs-commissioner-of-wealth-tax-on-17-february-1965\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Pramod Kumar Jain vs Commissioner Of Wealth-Tax, ... on 17 February, 1965 - 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