1. - By the reference application filed under section 27(1) of the Wealth-tax Act, 1957, Seth Mukund Das Rathi, the assessee, required the Tribunal to refer to the High Court of Judicature for Rajasthan at Jaipur, three questions which were enumerated in the application. The application was allowed partly and the following question was referred by the Tribunal to the High Court for its opinion :

"Whether, on the facts and in the circumstances of the case, the Tribunal was justified in not allowing deduction for the gratuity liability amounting to Rs. 12,79,000 from the total assets of the company as per balance-sheet as on December 31, 1972, while valuing the unquoted equity shares of M/s. Krishna Mills Ltd., Beawar, in accordance with rule 1D of the Wealth-tax Rules, 1957 ?"

2. The reference application pertained to the wealth-tax assessment for the year. 1974-75. The valuation date was October 26, 1973. The reference application was concerned with regard to the enhancement of the net wealth of Rs. 92,609.

3. The background in which the controversy arose was about the valuation of equity shares of Krishna Mills Limited, which was a public limited company. The number of share