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TMI Blog1984 (12) TMI 117X X X X Extracts X X X X X X X X Extracts X X X X ..... For the assessee Mr. Dani submitted that the assessee as well as his wife were employed by M/s Toshniwal Industries (P) Ltd., Ajmer and the assessee's wife a science graduate was in the employment of the company since 1972. The company manufactures scientific instruments. The company is a family concern in which the assessee's wife is a member. In the hands of the company the salary paid to the w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lating to scientific instruments. The assessee, therefore, said the possess technical qualification as far as the employment is concerned. Mr. Dani thereafter submitted the Tribunal's Judgment of Madras, Hyderabad and Ahmedabad, etc., where the qualification, the technical expertise and professional qualities have been examined. Relying on the these judgment, he submitted that the inclusion of sal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee to his wife. it is also accepted fact that the assessee and his wife received salary by virtue of their employment in a concern which is their family concern. by applying s. 64(1)(ii) it seems apparent that the assessee has substantial interest in the concern. The various judgments of the tribunal filed by the assessee indicate that s. 64(1)(ii) cannot apply to a case where the assessee's ..... X X X X Extracts X X X X X X X X Extracts X X X X
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