{"id":29070,"date":"1982-07-24T00:00:00","date_gmt":"1982-07-23T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982"},"modified":"2018-03-01T14:44:40","modified_gmt":"2018-03-01T09:14:40","slug":"master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","title":{"rendered":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982"},"content":{"rendered":"
Income Tax Appellate Tribunal – Mumbai<\/div>\n
Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982<\/div>\n
Equivalent citations: 1984 8 ITD 332 Mum<\/div>\n
Bench: V Balasubramanian, Vice, K Menon<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
V. Balasubramanian, Vice President<\/p>\n
1. The assessee owns certain shares of Nirmal Commercial Ltd. through the Sameer S. Somaiya Trust. The assessee had valued the shares of this company at Rs. 5 starting with a value of fixed assets at Rs. 91,84,875 and deducting liabilities of Rs. 83,51,205 due to the shareholders against premises allotted. Under the break-up method, the break-up value of the share was computed  at Rs. 8.65 and since there was no dividend declared on equity shares for six years and more, the market value was worked out at Rs. 6.50 being 75 per cent of the break-up value. Rounding it off, the assessee valued the assets at Rs. 5. The WTO revalued these assets. In so doing he did not accept the assessee’s contention that a sum of Rs. 83,51,205 deposits from shareholders were refundable to them. The WTO worked out the break-up value at Rs. 475.20 and having regard to the non-declaration of dividends for six years fixed the market value of the shares at Rs. 356.40. The assessee, who is the owner of 270 shares in this company, had calculated the excess of assets over expenditure in respect of these assets at Rs. 99,070. The value of the shares themselves was returned at Rs. 1,350. Valuing these shares at Rs. 356.40, the WTO worked out the market value of these shares at Rs. 94,878. He also added the sum of Rs. 1,31,500, the non-refundable fixed deposit due to the Nirmal Commercial Ltd. from the assessee, thus, with a small adjustment arriving at a figure of Rs. 2,26,270 to be added to the net wealth. In effect the WTO revalued the shares of Nirmal Commercial Ltd. by treating the non-refundable fixed deposit at Rs. 1,31,500 as not a liability in the first instance and also added to the value of the shares worked out by him the sum of Rs. 1,31,500, again as a deposit held by the assessee with the company. On appeal, the Commissioner (Appeals) confirmed the computation made by the WTO. In this regard both the valuation of the shares and the addition of Rs. 1,31,500 as an extra asset was confirmed. The present appeal is against the above order of the Commissioner (Appeals).\n<\/p>\n
2.  The learned counsel for the assessee has pointed  out that even  apart from the question of considering  the non-refundable deposits as such, there is a double addition in this case, the result of an inconsistent   view held by the authorities below.    While computing the break-up value of the shares, the WTO and the Commissioner (Appeals) treated the refundable deposit of Rs. 1,31,500 as really non-refundable so as to increase the assets of the company.  While computing the net wealth  of the assessee himself,  they  again added the sum  of Rs.  1,31,500 as an amount the assessee has to get from Nirmal Commercial Ltd.  If the latter proposition was correct, according to the learned counsel, certainly the first proposition was incorrect and vice versa.  It is pointed out that though originally the sum of Rs. 1,31,500 was treated as a non-refundable deposit by an appropriate resolution passed by the company, this view was revised and the amount was treated as a refundable  deposit.  The valuation by the break-up method of the shares given by the assessee  should, therefore, be accepted. The assessee has no objection in including the sum of Rs. 1,31,500 as extra amount due to the assessee from the company.\n<\/p>\n
3.  For the department stress  is laid  on   the orders  of the authorities below.\n<\/p>\n
4.  The assessee has been taking, according to the learned counsel  for the department, an inconsistent stand  that this amount was non-refundable in the first   instance and refundable   subsequently.   This was a purely private limited company confined to a group of persons  who could adjust their financial relations the way  they liked.   In   fact even taking an adjustment for non-declaration of dividend   for six  years and restricting the value of the shares to Rs. 6.50, the  assessee returned the actual value only at Rs. 5 which shows the very casual   manner in which the valuation has been made.\n<\/p>\n
5.  The facts before us read in the  background  of the   Wealth-tax Act, 1957 (‘the Act’) and the Wealth-tax Rules, 1957 (‘the rules’) leave us with no  doubt  that the  valuation  of these shares   and  the inclusion of the alleged non-refundable amount have not been done properly either by the assessee or by the  department.   In  the first place the business  of the company appears to be at best a single venture for  being construction of a set of fiats for which the company form  was adopted the would-be flat owners subscribing to the shares.    They have also paid  certain amounts originally stated to be non-refundable deposits in lieu of  the  allotment of flats to them.    Subsequently a  resolution  seems  to have been passed converting the non-refundable deposits into refundable  deposits. Both the parties assumed that Rule 1D  of the  rules   applies  to  the  case and the valuation of shares should  be made under   the  break-up method and adjustment for non-declaration of dividends for some time  was also agreed upon by the parties. As validly  contended by the learned counsel for the assessee, the WTO,  however,   adopted an inconsistent view with regard to the alleged deposits.    While computing   the value of the shares under the break-up method, he  treated   the deposit as  non-refundable, thus, enhancing the assets of the company and increasing the value of the shares.    Coming back to  the assessment of the  individual,  he treated the deposits as refundable and included them in the net wealth.   Certainly such   an inconsistent view cannot be upheld.    But a more basic problem in this computation of net wealth is that, in   our view,  neither the resort to Rule 1D nor the approach of both the   parties  to the  deposit amount seems to be correct.   Rule 1D is not  applicable to an investment company. It is admitted before us that the assessee,  a one  time builder of a specific number of flats for its shareholders,   has done no business but has only made an investment.    Admittedly, Rule  1D cannot be resorted to in valuing    shares  of this   company.    More important  than  that is the wavering stand both the assessee as well as the WTO have adopted with regard to the deposit with the company. If,  as the assessee contended, the original concept was that of a non-refundable deposit,  when the  assessee converted into a refundable deposit, here   was a clear case of a gift which might have been attracted the  Gift-tax Act,  1958, in the hands of the company-donor. Be that as it may, a   more interesting point is that the company could with no difficulty convert non-refundable deposit of nearly Rs. 1 lakh into a refundable deposit being a private limited company, the ultimate purpose of which is to construct flats for its own members. The company form has been adopted to achieve this end and the cost of the flats to the members have been bifurcated partly into shareholding and partly into a deposit, the nature of which has been wavering from non-refundable to refundable. Evidently here is a case where if tax adjustment or avoidance could be even the remotest intention of the members, the corporate veil must have been pierced to bring proper amount to tax. We particularly emphasise this point because of the case with which large amounts of money are being made refundable or non-refundable at the desire of the interested members. This group of members through the medium of the company whether by shareholding or by deposits got flats constructed and allotted to themselves and are in effect the owners of these flats. By wrongly sticking on to Rule 1D in a case where it may not apply, obviously these flat-holders are seeking to maintain the prices of their flats at the nominal value of the shares of the company, whereas their market value may be far higher than this. This will be against the valuation provisions of the Act. While, thus, on the one hand, the double consideration of the deposit may show an inconsistency, we have to hold that the very basis of valuation adopted by both the assessee and the department cannot be accepted as correct.\n<\/p>\n
6.  It was argued before us that when there is no dispute about the method of valuation or the applicability of Rule 1D between the  parties, the Tribunal  should not  refer to these matters or widen the issue.  The problem is not so simple. As the final fact-finding authority,  the Tribunal is bound to give a correct view on the correct   facts and the applicable law. We cannot be constrained by any agreement   between the parties as to the legal position or even a factual analysis  of any  situation if it is incorrect. It will be neither correct nor  fair for the Tribunal to give a decision almost in an abstract sense on a limited point when the basic premises as in the present case agreed between the parties   are not considered by the Tribunal to be  correct.   We, therefore,   think it proper to restore the matter to the file of the WTO with a direction   to approach the problem in the light of the above observations and   to compute the  value  of the assets  according to the correct facts and law.   The  WTO  should arrive at a correct nature  of the  asset  in the  present   case whether a mere shareholding or a flat or a share and deposit in a company  and then include the proper value of the assets in the net wealth.\n<\/p>\n
7. A doubt was expressed before us as to whether if the above recomputa-tion results in an enhancement  of  the net wealth   of the assessee,  the Tribunal could do it.   Under the Act the Tribunal has powers of enhancement.    It is also imperative  that if enhancement is   to be made,  the Tribunal must give an opportunity to the assessee to present his case before passing orders. Since we are not sure that there will be a real enhancement in this case after the WTO has gone into the details. The stage for giving an enhancement notice, if any, has not, therefore, arrived. If the WTO finds that the value he has to adopt is in excess of the original figure of assessment, he must issue a proper notice to the assessee inviting his attention to the enhancement, hear his representations and then complete the assessment. The principle of natural justice, which requires a hearing before the enhancement would, in our opinion, be satisfied if the assessee has a bearing on this point even at an earlier stage where the question of increase comes up. If, however, the assessee wants a hearing by us, he may approach us in what will be a mere continuation of these proceedings and not a separate hearing.\n<\/p>\n
8. For statistical purposes, the appeal is allowed.<\/p>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Mumbai Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 Equivalent citations: 1984 8 ITD 332 Mum Bench: V Balasubramanian, Vice, K Menon ORDER V. Balasubramanian, Vice President 1. The assessee owns certain shares of Nirmal Commercial Ltd. through the Sameer S. Somaiya Trust. The assessee had […]<\/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":[1],"tags":[],"class_list":["post-29070","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nMaster Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - 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\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"og:url\" content=\"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\" \/>\n<meta property=\"og:site_name\" content=\"Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"article:publisher\" content=\"https:\/\/www.facebook.com\/LegalindiaCom\/\" \/>\n<meta property=\"article:published_time\" content=\"1982-07-23T18:30:00+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2018-03-01T09:14:40+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1\" \/>\n\t<meta property=\"og:image:width\" content=\"512\" \/>\n\t<meta property=\"og:image:height\" content=\"512\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"author\" content=\"Legal India Admin\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:creator\" content=\"@legaliadmin\" \/>\n<meta name=\"twitter:site\" content=\"@Legal_india\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Legal India Admin\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"9 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#article\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\"},\"author\":{\"name\":\"Legal India Admin\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/person\\\/0bfdffe9059fb8bb24a86d094609c5ea\"},\"headline\":\"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982\",\"datePublished\":\"1982-07-23T18:30:00+00:00\",\"dateModified\":\"2018-03-01T09:14:40+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\"},\"wordCount\":1825,\"commentCount\":0,\"publisher\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\"},\"articleSection\":[\"Judgements\"],\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"CommentAction\",\"name\":\"Comment\",\"target\":[\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#respond\"]}]},{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\",\"name\":\"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#website\"},\"datePublished\":\"1982-07-23T18:30:00+00:00\",\"dateModified\":\"2018-03-01T09:14:40+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#website\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\",\"name\":\"Free Judgements of Supreme Court & High Court | Legal India\",\"description\":\"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.\",\"publisher\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\"},\"alternateName\":\"Free judgements of Supreme Court & High Court of India | Legal India\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#organization\",\"name\":\"Judgements of Supreme Court & High Court | Legal India\",\"alternateName\":\"Legal India\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/wp-content\\\/uploads\\\/sites\\\/5\\\/2025\\\/09\\\/legal-india-icon.jpg\",\"contentUrl\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/wp-content\\\/uploads\\\/sites\\\/5\\\/2025\\\/09\\\/legal-india-icon.jpg\",\"width\":512,\"height\":512,\"caption\":\"Judgements of Supreme Court & High Court | Legal India\"},\"image\":{\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/logo\\\/image\\\/\"},\"sameAs\":[\"https:\\\/\\\/www.facebook.com\\\/LegalindiaCom\\\/\",\"https:\\\/\\\/x.com\\\/Legal_india\"]},{\"@type\":\"Person\",\"@id\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/#\\\/schema\\\/person\\\/0bfdffe9059fb8bb24a86d094609c5ea\",\"name\":\"Legal India Admin\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"url\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"contentUrl\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"caption\":\"Legal India Admin\"},\"sameAs\":[\"https:\\\/\\\/www.legalindia.com\",\"https:\\\/\\\/x.com\\\/legaliadmin\"],\"url\":\"https:\\\/\\\/www.legalindia.com\\\/judgments\\\/author\\\/legal-india-admin\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","og_locale":"en_US","og_type":"article","og_title":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India","og_url":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","og_site_name":"Free Judgements of Supreme Court & High Court | Legal India","article_publisher":"https:\/\/www.facebook.com\/LegalindiaCom\/","article_published_time":"1982-07-23T18:30:00+00:00","article_modified_time":"2018-03-01T09:14:40+00:00","og_image":[{"width":512,"height":512,"url":"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1","type":"image\/jpeg"}],"author":"Legal India Admin","twitter_card":"summary_large_image","twitter_creator":"@legaliadmin","twitter_site":"@Legal_india","twitter_misc":{"Written by":"Legal India Admin","Est. reading time":"9 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#article","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982"},"author":{"name":"Legal India Admin","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea"},"headline":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982","datePublished":"1982-07-23T18:30:00+00:00","dateModified":"2018-03-01T09:14:40+00:00","mainEntityOfPage":{"@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982"},"wordCount":1825,"commentCount":0,"publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"articleSection":["Judgements"],"inLanguage":"en-US","potentialAction":[{"@type":"CommentAction","name":"Comment","target":["https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#respond"]}]},{"@type":"WebPage","@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","url":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982","name":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/#website"},"datePublished":"1982-07-23T18:30:00+00:00","dateModified":"2018-03-01T09:14:40+00:00","breadcrumb":{"@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982"]}]},{"@type":"BreadcrumbList","@id":"https:\/\/www.legalindia.com\/judgments\/master-sameer-s-somaiya-vs-first-wealth-tax-officer-on-24-july-1982#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/www.legalindia.com\/judgments\/"},{"@type":"ListItem","position":2,"name":"Master Sameer S. Somaiya vs First Wealth-Tax Officer on 24 July, 1982"}]},{"@type":"WebSite","@id":"https:\/\/www.legalindia.com\/judgments\/#website","url":"https:\/\/www.legalindia.com\/judgments\/","name":"Free Judgements of Supreme Court & High Court | Legal India","description":"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.","publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"alternateName":"Free judgements of Supreme Court & High Court of India | Legal India","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/www.legalindia.com\/judgments\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/www.legalindia.com\/judgments\/#organization","name":"Judgements of Supreme Court & High Court | Legal India","alternateName":"Legal India","url":"https:\/\/www.legalindia.com\/judgments\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/","url":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","contentUrl":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","width":512,"height":512,"caption":"Judgements of Supreme Court & High Court | Legal India"},"image":{"@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/"},"sameAs":["https:\/\/www.facebook.com\/LegalindiaCom\/","https:\/\/x.com\/Legal_india"]},{"@type":"Person","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea","name":"Legal India Admin","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","url":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","caption":"Legal India Admin"},"sameAs":["https:\/\/www.legalindia.com","https:\/\/x.com\/legaliadmin"],"url":"https:\/\/www.legalindia.com\/judgments\/author\/legal-india-admin"}]}},"modified_by":null,"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"jetpack_likes_enabled":true,"jetpack-related-posts":[],"_links":{"self":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/29070","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/comments?post=29070"}],"version-history":[{"count":0,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/29070\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/media?parent=29070"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/categories?post=29070"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/tags?post=29070"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}