9911796707
TMI Blog1970 (4) TMI 40X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,50,000 due to the assessee as accrued interest as at the valuation date was includible in the net wealth of the assessee ? " The assessee is a Hindu undivided family. The year of assessment is 1962-63, and the relevant date of valuation is March 31, 1962. Admittedly, the assessee is also assessed to income-tax and maintains the cash system of accounting. The assessee did not include a sum of Rs. 1,50,000 which had accrued due by way of interest on money-lending business by the date of valuation, but had not been received by the assessee until then, in its wealth-tax return. The stand taken by the assessee was that the amount having not been received it could not be taken into account for determining the net wealth as defined under secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... may, instead of determining separately the value of each asset held by the assessee in such business, determine the net value of the assets of the business as a whole having regard to the balance-sheet of such business as on the valuation date and making such adjustments therein as the circumstances of the case may require " (Underlining ours.) There is no dispute in this case that the assessee has maintained accounts regularly and, as the Appellate Tribunal has indicated, there is a balance-sheet of such business as on the valuation date. The assessee did not include the interest on money-lending business accrued to it on the date of valuation as the same had not been received and a balance-sheet prepared on the cash basis of accounts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... venue that under the Wealth-tax Act in the case of an assessee who maintains its accounts and prepares the balance-sheet on cash basis, accrued income not received would still be taken into account. It is quite possible that the interest in question which has accrued to the assessee may turn out to be a bad debt in whole or part and thus, though accrued due, may not at all be received by the assessee. It can never be said to have been the intention of Parliament to include the same in the computation of net wealth in respect of an assessee who maintains its accounts on cash basis. In the case of the mercantile system of accounting the position would be quite different. While income accrued and yet not received would be taken into account de ..... X X X X Extracts X X X X X X X X Extracts X X X X
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