JUDGMENT

P. N. BHAGWATI, J.:—These appeals by special leave raise a short question as to whether a reference should have been called for by the High Court in each of these cases. Some of these cases are under the Gift Tax Act while others under the Wealth Tax Act. They all relate to the valuation of the ordinary shares of a private limited company called Mafatlal Gagalbhai Pvt. Ltd. which is admittedly an investment company: The assessee in these cases claimed in the course of assessments to gift tax or wealth tax, as the case may be that the value of the shares should be taken to be the figure arrived at by M/s. C. C. Choksy & Co., Chartered Accountants, by applying the profit earning method of valuation of shares without making any adjustment in the profits of the company. It is not necessary for the purpose of these appeals to set out the different figure of valuation given in the report of M/s. C. C. Choksy & Co. and claimed by the assessees as representing the correct value of the shares on the material dates, because the question with which we are concerned is one of principle and the actual figures of valuation are not relevant. The Gift Tax and Wealth Tax Officers did not a