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Issues Involved:
1. Ownership of properties agreed to be sold but not executed or registered. 2. Ownership of properties in possession of Sahebzadas and Sahebzadis granted by firmans. 3. Inclusion of Rs. 25,00,000 receivable from the State Government in net wealth under the Wealth-tax Act, 1957. 4. Inclusion of Rs. 13,00,578 representing accrued interest and rentals in net wealth for the assessment year 1964-65. Issue-wise Detailed Analysis: 1. Ownership of Properties Agreed to be Sold but Not Executed or Registered: The court examined whether the assessee was the owner of properties for which sale consideration was received but no sale deeds were executed or registered. The learned standing counsel referenced decisions in CIT v. Nawab Mir Barkat Ali Khan [1974] and Nawab Mir Barkath Ali Khan v. CIT [1988], which held against the assessee. However, the assessee's counsel cited CIT v. Sahney Steel and Press Works (P.) Ltd. [1987], which considered the Supreme Court's judgment in Nawab Sir Mir Osman Ali Khan v. CWT [1986] but relied on Jodha Mal Kuthialia (R. B.) v. CIT [1971]. The court noted a conflict of opinion between two Division Benches regarding the interpretation of "transfer" under section 4 of the Wealth-tax Act. The court decided to refer this question to a larger Bench for an authoritative pronouncement. 2. Ownership of Properties in Possession of Sahebzadas and Sahebzadis Granted by Firmans: The court considered whether the assessee was the owner of properties in possession of Sahebzadas and Sahebzadis, granted by firmans. The learned counsel for the assessee referenced Nawab Mir Barkath Ali Khan v. CIT [1988], but the standing counsel for the Revenue argued that the necessary factual basis regarding the date of the firman was not recorded. The court observed that the definition of "transfer" in the Explanation to section 4 of the Act was not considered in the earlier case. Due to the recurring nature and importance of this issue, the court decided to refer this question to a larger Bench. 3. Inclusion of Rs. 25,00,000 Receivable from the State Government in Net Wealth: The court addressed whether the assessee's right to receive Rs. 25,00,000 from the State Government constituted an asset for inclusion in the net wealth. The learned counsel for the assessee cited the Supreme Court's judgment in Nawab Sir Mir Osman Ali Khan v. CWT [1986], which was not disputed by the Revenue's counsel. Therefore, the court answered this question in the negative, in favor of the assessee and against the Revenue. 4. Inclusion of Rs. 13,00,578 Representing Accrued Interest and Rentals in Net Wealth: The court considered whether Rs. 13,00,578 representing accrued interest and rentals due could be considered part of the net wealth for the assessment year 1964-65. This question was covered by the court's judgment in Vadrevu Venkappa Rao v. CWT [1968], and there was no dispute. Therefore, the court answered this question in the affirmative, in favor of the Revenue and against the assessee. Conclusion: The court referred questions 1 and 2 to a larger Bench due to conflicts and the need for an authoritative pronouncement. Questions 3 and 4 were answered in favor of the assessee and the Revenue, respectively. The reference was accordingly answered, and no order as to costs was made.
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