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Issues:
Challenge to order passed by Commissioner of Wealth-tax under section 25(1) of the Wealth-tax Act, 1957 regarding exemption for amounts deposited in compulsory deposit scheme. Analysis: The petitioners challenged the Commissioner's order refusing to entertain their revision application under section 25 of the Wealth-tax Act, 1957. They contended that the amounts deposited under the Compulsory Deposit Scheme should be exempted as they were repayable in five equal instalments with interest, constituting an annuity. The Inspecting Assistant Commissioner had treated these amounts as wealth-tax assets, but the petitioners relied on a Tribunal decision stating otherwise. Upon considering the submissions, the court noted that the petitioners were obligated to make specified deposits under the Act, repayable in instalments with prescribed interest. Referring to the Supreme Court's definition of "annuity" in a previous case, the court determined that the repayments under the compulsory deposit scheme qualified as an annuity, meeting the criteria of fixed, periodic payments. This annuity was deemed exempted under section 2(e)(2)(ii) of the Wealth-tax Act. Consequently, the court held that the petitioners were entitled to exemption for the amounts deposited in the compulsory deposit scheme. The Commissioner's order was quashed and set aside, ruling in favor of the petitioners. The petition was allowed, and costs were not awarded. In conclusion, the judgment revolved around the interpretation of the term "annuity" in the context of amounts deposited in a compulsory deposit scheme under the Wealth-tax Act. The court's decision emphasized the fixed and periodic nature of repayments, ultimately granting the petitioners the exemption they sought and overturning the Commissioner's order.
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