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Issues:
Impugning notices under section 17 of the Wealth-tax Act for assessment years 1975-76 to 1978-79 based on wealth "escaped assessment." Failure to disclose pending application under section 18 of the Land Acquisition Act. Jurisdiction of respondent authorities in issuing notices. Analysis: The petitioner challenged notices issued under section 17 of the Wealth-tax Act for the assessment years 1975-76 to 1978-79, alleging wealth had "escaped assessment." The petitioner, an agriculturist, had his land acquired by Military Authorities in 1974, leading to enhanced compensation. The petitioner's failure to disclose the pending application under section 18 of the Land Acquisition Act was a key issue. The District Judge enhanced compensation, which the petitioner contested in court, resulting in a higher compensation amount. The petitioner did not disclose these proceedings in his tax returns. The respondent authorities argued non-disclosure of pending land acquisition proceedings affected the assessment. The petitioner's counsel contended that the Wealth-tax Officer was aware of the compensation received, and the notices were without jurisdiction. The Andhra Pradesh High Court judgment highlighted the obligation to disclose pending land acquisition proceedings. The Supreme Court emphasized the evaluation of compensation for tax purposes based on the relevant date. The court held that once the compensation was evaluated and taxed, subsequent enhancements could not be reconsidered for earlier years. The court concluded that the enhanced compensation was not taxable wealth for the relevant years, ruling in favor of the petitioner. The respondent authorities suggested the court should not adjudicate on the case's merits, urging the petitioner to seek remedies under the Act. However, since the court's conclusion favored the petitioner, this argument was rejected. The court allowed the petition, setting aside the impugned notices without costs.
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