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The High Court of Delhi allowed the petition under section 27(3) of the Wealth-tax Act, 1957, converting it into a reference. The court held that the market value of shares should be determined using the break-up value under rule 1D of the Wealth-tax Rules, 1957, rather than the yield method. This decision was based on the Supreme Court's ruling in Bharat Hari Singhania v. CWT [1994] 207 ITR 1, reversing the earlier decision in Sharbati Devi Jhalani v. CWT [1986] 159 ITR 549. The question of law was answered in the negative, in favor of the Revenue and against the assessee.
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