B. P. JEEVAN REDDY, CJ.

( 1 ) UNDER Section 27 (3) of the Wealth-tax Act, 1957, the Tribunal referred the following four questions :

1. "whether, on the facts and in the circumstances of the case, Rule 1d of the Wealth-tax Rules, 1957, overrides the provisions of Section 24 (6) of the Wealth-tax Act ?

( 2 ) WHETHER, on the facts and in the circumstances, is it open to the Revenue to rely on Rule 1d even though no specific argument was raised before Tribunal ?

( 3 ) WHETHER, on the facts and in the circumstances of the case, the Tribunal was justified in adopting the valuation as made by the; valuers even though their valuation was not based on the statutory method of valuation provided under Rule 1d?

( 4 ) WHETHER the valuers to whom the valuation of shares was referred under Section 24 (6) of the act were, in law, bound to follow the method of valuation prescribed by Rule 1d of the wealth-tax Rules ?

"2. The assessee is an individual. She held certain unquoted shares of various companies of the j. K. Group In her returns filed under the Wealth-tax Act, she valued those shares by taking the average of the breakup value method and the yield value method. This was not accepted by the weal

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