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Issues:
1. Challenge to order of Commissioner of Wealth-tax 2. Interpretation of s. 5(1)(viii) of the Wealth Tax Act 3. Revision petitions filed by petitioners 4. Exercise of revisional powers by Commissioner 5. Claiming exemption under s. 5(1)(viii) of the Act 6. Existence of sufficient cause for delay in filing revision petitions Analysis: The judgment delivered by the High Court of Delhi pertains to three writ petitions filed by Hindu wives who are assessed to wealth tax, challenging an order by the Commissioner of Wealth-tax. The petitioners contested the order dated October 3, 1970, which dismissed their revision petitions under s. 25 of the Wealth Tax Act, 1957. The revision petitions were filed subsequent to a Supreme Court decision in the case of CWT v. Arundhati Balkrishna, where it was clarified that s. 5(1)(viii) of the Act provides for exemption for jewellery intended for personal use of the assessee. The Commissioner dismissed the revision petitions on the grounds of being time-barred and lack of sufficient cause preventing the petitioners from challenging their assessment orders within the stipulated time. The court outlined the scheme of the Wealth Tax Act, emphasizing the hierarchy of authorities, provisions for appeals, revisions, and references akin to the Income Tax Act, 1961. It noted that the petitioners did not claim exemption under s. 5(1)(viii) in their returns, which were accepted by the Wealth Tax Officer. The court analyzed the provision of s. 25(1) of the Act, which confers revisional powers upon the Commissioner. The petitioners argued that they were under a bona fide mistake regarding the exemption for jewellery before the amendment to s. 5(1)(viii), and that the delay in filing the revision petitions was justified due to the recent Supreme Court judgment. However, the court found that the revision petitions were misconceived as the petitioners never claimed exemption before filing them, and there was no locus standi for approaching the Commissioner through revision petitions. The court held that the petitioners had no merit in their writ petitions, as there was no valid reason preventing them from approaching the Commissioner within the specified time for revision. It emphasized that the interpretation of the law by a superior court in a different case does not automatically constitute sufficient cause for delay. Ultimately, the court dismissed the writ petitions with costs, concluding that there was no justification for the delay in filing the revision petitions and that the petitioners had not claimed the exemption as required by law.
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