B.C. MITRA, A.M. assessee is partner of M/s Associated Rope and Cable Co., Dhanbad. assessee had half share in certain properties which were used by firm for its business. value of these properties were, however, reflected in firm's balance-sheet. assessee claimed exemption under s. 5(1) (iv) in respect of value of her interest in immovable properties that was shown in firm's account. ITO negatived assessee's claim for deduction under s. 5(1) (iv) amounting to Rs. 32,787, Rs. 33,776, Rs. 39,700, Rs. 35,565 and Rs. 36,374 respectively for asst. yrs. 1976-77 to 1980-81. AAC directed WTO to allow exemption under s. 5(1)(Iv) of WT Act as claimed by assessee for each of asst. yrs. 1976-77 to 1980-81 bby following Patna High Court decision in case of CWT, Bihar vs. Nand Lal Jalan (1980) 14 CTR (Pat) 181: (1980) 122 ITR 781 (Pat). Another point in dispute was that t h e WTO estimated value of assessee's jewellery wrongly at Rs. 2,99,000, Rs. 3,26,000, Rs. 3,80,000 and Rs. 5,17,000 for asst. yrs. 1977- 78, 1978-79, 1979-80 and 1980-81 respectively. AAC on basis of assessee's approved valuer's reports for each of valuation dates ending on last day of calendar years relevant for asst. yrs. 1977-78 to 1980-81 allowed relief of Rs. 27,303, Rs. 16,000, Rs. 38,762 and Rs. 89,444 respectively. Against said consolidated order of AAC dt. 16th March, 1983 Department has come up in appeals against both relief allowed by AAC under s. 5(1)(Iv) of WT Act and in respect of reduction allowed in value of jewellery estimated by WTO. assessee, on other hand has, filed cross objections in support of AAC's orders. Since common contentions have been raised in departmental appeals relating to asst. yrs. 1976-77 to 1980-81 both Revenue's appeals and cross objections of assessee are disposed of by this consolidated order for sake of convenience. In respect of first common point whether AAC was justified in allowing exemption under s. 5(1)(Iv) of WT Act, AAC's order does not require any interference as his order is based on Patna High Court decision in case of Nand Lal Jalan (supra) which is binding on officers of Department working in Bihar. In regard to second ground, viz., that AAC was not justified in reducing value of jewellery estimated by WTO, ld. Counsel submitted before us that in asst. yr. 1976-77 WTO accepted value of jewellery as shown in return at Rs. 2,92,947 which was based on approved valuer's report in respect of valuation date ending 31st March, 1976. It has been stated that WTO did not accept value shown by assessee in her returns for subsequent years, since no separate valuation report for asst. yrs. 1977-78 to 1980-81 has been filed before WTO. assessee submitted before AAC approved valuer's reports as on last day of calendar years relevant for asst. yrs. 1977-78 to 1980-81. In reply departmental representative supported WTO's orders and it was pointed out that assessee having failed to furnish valuation report before WTO AAC was wrong in accepting fresh evidence in violation of s. 5A(3) of WT Rules. On due consideration of submissions made by parties concerned, we are of opinion that AAC's order does not require any interference for simple reason that order is based on report of expert that was submitted before him by assessee. It has been pointed out by assessee's ld. Counsel that for asst. yr. 1981-82 WTO accepted value shown at Rs. 2,63,847 based on same approved valuer's report. In our opinion, it is of no consequence whether WTO or AAC considered approved valuer's report inasmuch as none of authorities can legally discard expert's opinion without obtaining another opinion from expert. In circumstances of case, AAC having considered valuer's report as on valuation dates relevant for asst. yrs. 1977-78 to 1980-81, we do not find any ground to interfere with AAC's order in this regard. AAC's order is, accordingly, upheld. departmental appeals and cross objections are dismissed. *** WEALTH-TAX OFFICER v. SMT. RADHA DEVI AGARWALLA