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TMI Blog2015 (4) TMI 1316X X X X Extracts X X X X X X X X Extracts X X X X ..... s claim on the ground that the assessee has not been able to prove that the debt was Incurred in relation to the motor cars - HELD THAT:- The assessee has referred to the balance sheet of the assessee as on the valuation date from which it is evident that the share capital and reserves and surplus taken together is ₹ 45.88 crores while the accumulative loss was ₹ 85.73 crores. Therefore, all the assets of the assessee company have been acquired out of the loan funds only. When the assessee has no funds of its own, then, in our opinion, the Assessing Officer was not justified in denying the deduction under Section 2(m) to the assessee - W.T.A. No. 8/Del/2014 - - - Dated:- 29-4-2015 - SHRI R.S. SYAL, ACCOUNTANT MEMBER AND SHRI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion thereof. 2.2 That the CIT(A) failed to appreciate that the financial position / results of the appellant clearly exhibits that the loans were actually incurred in relation to the specified taxable assets. That the appellant craves leave to add, alter, amend or vary from the aforesaid grounds of appeal before or at the time of hearing. 2. The facts narrated by the Revenue Authorities are not disputed, therefore, need not be repeated here for the sake of convenience. 3. At the time of hearing, Ld. Counsel of the assessee stated that the issues in dispute have already been adjudicated and decided by the ITAT, Delhi Bench E , New Delhi in assessee s own case for the asstt. year 2008-09 on 26.9.2014. He has also attached a copy ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r carsat ₹ 92.97 lakhs as against ₹ 76.54 lakhs declared by the assessee. We find that the Assessing Officer had valued the motor cars as per Rule 14(2)(a)(i) of Schedule-III of the Wealth Tax Act, 1957. That the Schedule-III of the Wealth Tax Act provides the rules for the valuation of the assets. The Assessing Officer has valued the assets as per rules prescribed under the Act for the valuation of assets. In view of the above, we find no merit in ground No.1, 1.1 1.2 of the assessee s appeal. The same are rejected. 4. Ground No.2, 2.1 2.2 of the assessee s appeal are against the non-allowance of deduction for the debt owed by the assessee in respect of taxable assets. It was claimed by the assessee that the debt owed by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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