TMI Blog1987 (12) TMI 82X X X X Extracts X X X X X X X X Extracts X X X X ..... t. yr. 1984-85 for which the relevant valuation date was 31st March, 1984. The assessee herein is HEH the Nizam's Jewellery for family Trust. The original assessment against the assessee-trust for asst. yr. 1984-85 was completed on 8th Feb., 1985. In the said assessment the assessee was granted exemption to the extent of Rs. 5 lakhs under s. 5 (1) (xvid) of the WT Act. However, after completion of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s were issued from 28th June 1982. The notification above referred to relating to the issue of 7 percent Capital Investment Bonds was found printed in (1982) 137 ITR (Stat) pp. 17, 18, 19, 20, 21 and 22. Rule 4 (3) speaks about the date of issue of the Bonds. The said sub-rule reads as follows: "The date of issue of Bonds will be the date of receipt of the subscription in cash or the date of rea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interest will be paid only on the 1st January. In this case the assessee trust purchased Capital Investment Bonds for the value of Rs. 5 lakhs. Demand draft dt. 27th March 1984 drawn on the United Bank of India Secunderabad was taken and was deposited with the Reserve Bank of India along with an application form duly filled in and signed on 29th March, 1984. So according to the assessee-trust the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the Bond was paid by him was the criterion for getting tax exemption it is futile to give undue importance to the date of issue of the Bond on 5th April, 1984. Clause No. 4(3) clearly shows that date of issue of the Bond will be the date of realisation of the cheque or the draft. Here in this case a draft was taken from the United Bank of India, Secunderabad for Rs. 5 lakhs on 27th March 1984 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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