Judgment : 1. THE Income-tax Appellate Tribunal (Allahabad Bench) referred the following question for the assessment year 1975-7C to this court for its opinion : "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that in working out the fair market value of the assets for their inclusion in the assessee's net wealth under the Wealth-tax Act, 1957, deduction cannot be allowed of the estimated notional capital gains tax in the event of the sale of those assets ?'" 2. THE Tribunal reached a conclusion following a decision of this court in the case of Bharat Hari Singhania v. CWT [1979] 119 ITR 258 and following that decision concluded that while for working out the fair market value of the assets for inclusion in the assessee's net wealth under the Wealth-tax Act, 1957, deduction cannot be allowed of the estimated notional capital gains tax in the event of sale of those assets. THE said judgment has been affirmed by the Supreme Court in Bharat Hari Singhania v. CWT [1994] 207 ITR 1. Following the said decision, we answer the aforesaid question in the affirmative, i.e., in favour of the Revenue and against the assessee.