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The High Court of Kerala rejected the Revenue's application under section 27(3) of the Wealth-tax Act, 1957. The Income-tax Appellate Tribunal's decision granting exemption under section 5(1)(xxxii) to the assessee, a partner in firms dealing in jewellery, was upheld. The Tribunal's finding that the firms were engaged in manufacturing new gold jewellery from old gold ornaments was considered a factual finding, and no question of law arose. The Revenue's submission that the firms were only polishing old gold ornaments was dismissed. The application was rejected.
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