TMI Blog1980 (2) TMI 116X X X X Extracts X X X X X X X X Extracts X X X X ..... e WT Act, 1957. 2. The WTO took the view that these coins were the commercial utility and were not puja coins as contended by the assessee. Accordingly, he included the amount of Rs. 9000 in the net wealth of the assessee. 3. The assessee appealed to the AAC of wealth tax. It was contended that the coins in question were of different ages and were not intended for sale. It was further contende ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eliance was placed on the commentary by Gulnikar on this point in the work titled as Two Acts, 1976 edition, which has been relied on by the AAC in his order under appeal. 6. We have carefully considered the submissions of the parties. On facts, there is no dispute that these silver coins are first issues of coins by the mint right from the time of QueenVictoria. These coins are made of silver a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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