(Reference under Section 27(3) of the Wealth-tax Act, by Income Tax Appellate Tribunal, Madras, 'D' Bench in W.T.A. Nos.102, 192(Mds)/90 and 357 & 206(Mds)/1991 dated 27.01.1993, for the assessment years 1984-85 and 1985-86. )

P.P.S. Janarthana Raja, J.

Income Tax Appellate Tribunal (hereinafter referred to as the "Tribunal"), Madras, 'D' Bench referred the matter under Section 27(3) of the Wealth-tax Act, as per the direction of this Court in T.C.P. Nos.202 to 205/97 dated 08.09.1998, for opinion of this Court.

2. The facts leading to the above tax cases are as under:

i) The assessee is a company in which the public are substantially interested. It is a closely held company. The relevant assessment years are 1984-85 and 1985-86 and the corresponding valuation dates are 31.03.1984 and 31.03.1985. The issue involved in these appeals relate to the assessment of multi storeyed building belonging to the assessee company. The property is at No.26, Commander-in-Chief Road, Chennai consisting of land to an extent of 26.65 grounds with a six storeyed building on a built-up area of 469 Sq.M. There is also another old building of 818 Sq.M. at the back. Of the total area of 26.65 gro