JUDGMENT

1. The question of law involved in this case is as follows:

"Whether the ld. ITAT was right in directing the Assessing Officer to disregard the recent valuation report and adopt old valuation report inspite of the fact that current valuation of the assets was available with the assessee at the time of filing of Wealth Tax return?

2. The assessees were subjected to search under Section 132 of the Income Tax Act, 1961 on 20.01.2012. Based upon the valuation of their assets, which included jewellery, the Wealth Tax Officer (WTO) made additions in excess of Rs.88 lacs which resulted in wealth tax liability. The challenge to the Commissioner of Wealth Tax was unsuccessful. Consequently, they appealed to the Tribunal which granted relief, based upon a circular issued on 15.03.1993.

3. It is urged on behalf of the Revenue that the circular in this case merely allows the assessee to use the report of the registered valuer obtained for one assessment year to assess the value of jewellery for subsequent four assessment years but under no circumstances it undermines the power of the Wealth Tax Officer to rely upon the later valuation report. The assessees resist the appeal; apa