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Issues:
1. Discrepancy in asset valuation between assessee and Commissioner (Appeals). 2. Valuation of land in the name of the assessee's wife. 3. Inclusion of sales price of land in the assessment. 4. Inclusion of seized cash in the assessment. Analysis: 1. The first issue pertains to the valuation of assets for assessment years 1976-77 and 1977-78. The appeals raised concern over the Commissioner (Appeals) not accepting the declared values of certain assets by the assessee. The Tribunal noted minor variations in the values shown and assessed, particularly in the case of land owned by the wife. The Tribunal declined to interfere with the values fixed by the Commissioner (Appeals) except for the land at Nai Sarak, where the Tribunal directed the value to be maintained at Rs. 1,25,000, in line with gift-tax assessment principles. 2. The second issue revolves around the valuation of land in the name of the assessee's wife, specifically 6 Bighas and 16 Biswa. The Commissioner (Appeals) accepted the value as declared by the assessee, leading the Tribunal to conclude that no injustice was done. The Tribunal also highlighted an inconsistency regarding the adoption of an average sale price for unsold land, ultimately declining to interfere with the valuation. 3. The third issue concerns the inclusion of the sales price of a portion of land in the assessment for the years 1976-77 and 1977-78. The Commissioner (Appeals) justified the inclusion based on the ownership of the land and the taxation of capital gains. The Tribunal concurred with the Commissioner (Appeals) and confirmed the inclusion of the sales proceeds in the total wealth of the assessee. 4. The final issue addresses the inclusion of seized cash in the assessment for the years 1976-77 and 1977-78. The assessee initially offered the amount as part of their wealth, but later discovered that the Department had adjusted the cash against outstanding demands. The Tribunal found no amount of seized cash remaining unadjusted with the Department and directed the deletion of the sum from the assessment. However, the Tribunal noted that if any amount of the seized cash was found unadjusted upon verification, it could be added to the assessee's wealth. The appeals for these years were partly allowed, subject to these considerations. In conclusion, the Tribunal's judgment addressed discrepancies in asset valuation, the inclusion of sales proceeds in the assessment, and the treatment of seized cash, providing detailed reasoning and directions for each issue across the assessment years in question.
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