Per Shri George Cheriyan, Vice President - These appeals are by the assessee. They relate to the assessment years 1972-73 to 1975-76. Since a common issue is involved, they are disposed of by this order. The assessee is the karta of a HUF. The facts as ascertained are that the assessee paid out of his individual funds an amount of Rs. 7,948 towards tax of the HUF. This was the amount of tax paid relevant to the valuation date 31-3-1972. Thereafter, another amount of Rs. 3,816 was paid in the previous year for which the valuation date was 31-3-1975. Thus, for each of the assessment years 1972-73 to 1974-75, the WTO held that under the provisions of section 4(1A) of the Wealth-tax Act, 1957 (‘the Act’) the amount of Rs. 7,948 has to be considered as the assessee’s wealth since the property of the assessee had been impressed with the nature of HUF property. The plea of the assessee that no property remained in existence and, therefore, nothing could be included in the, net wealth was not accepted by the WTO. He thus brought to tax Rs. 7,948 in each of the assessment years 1972-73 to 1974-75 and in 1975-76, he brought to tax Rs. 11,764.

2. The assessee appealed. Emphasis was placed