This second appeal is directed against order dated 16-11-1984 passed by AAC, 'O' Range, New Delhi dismissing assessee's appeal in respect of addition of Rs. 6 lakhs made in assessment framed on 19-10-1982 under section 16(3) of Wealth-tax Act, 1957 ('the Act') in respect of assessment year 1978-79, for which valuation date was 31-3-1978. question is whether assessee was rightly denied exemption under section 5(1)(xxiii) of Act, in relation to Rs. 6 lakhs, which was remitted in favour of U.P. Twiga Fibreglass Ltd. ('the company') for allotment of shares. 2. appellant, Indian by origin, was admittedly British citizen and admittedly Rs. 6 lakhs was remitted from abroad for allotment of shares of company. It is also undisputed that shares were allotted after valuation date after approval from Reserve Bank of India. 3. To understand assessee's claim and basis of lower authorities decision, related provision should be brought in close focus and, therefore, reproduced below: "5. (1) Subject to provisions of sub-section (1A), wealth-tax shall not be payable by assessee in respect of following assets, and such assets shall not be included in net wealth of assessee-- (xxiii) any shares not being shares referred to in clause (xx) or clause (xxa) in any Indian company where assessee is individual or Hindu undivided family;" 4. From plain reading of above, it is clear that mandate of provision is that exemption would be available in respect of shares. assessee's case has been that share application money should be equated with shares applied for and allotted even after valuation date. assessing officer did not go into any controversy and denied exemption by simply stating as follows: "Non-interest bearing amount standing with U.P. Twigs Fibreglass Ltd. Rs. 6,00,000." AAC upheld assessment on point by observing that since no shares as such had been allotted till valuation date, there was no question of any exemption as claimed. 5. Though as per evidence on record registered hearing notice has been served on address given in memorandum, we found no arrangement for representation on appeal being called on for hearing, for revenue Mrs. Shashi Kapila was present to assist us. Finding no justification for ordering fresh hearing date, appeal is being decided exercising our discretion under rule 24 of Income-tax (Appellate Tribunal) Rules, 1963. 6. According to us, share application money by no stretch of imagination can be considered as same thing as shares. There is no indication or any mandate even by implication that different treatment should be meted out, when money is remitted from abroad for allotment of shares because in all such cases there is bound to be spacing between intention to buy shares and actual allotment. 7. On facts, therefore, authorities rightly denied assessee's claim and there is no occasion to interfere. Appeal dismissed. *** ALIM SHAMJI v. WEALTH-TAX OFFICER