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TMI Blog1980 (10) TMI 138X X X X Extracts X X X X X X X X Extracts X X X X ..... nd (2) for adopting two years purchase price instead of three years in respect of the firm M/s Shantilal Ramchand Shah. Shri Ramchand. Bhaichand of Solapur died on 30th April, 1975. He was a partner in two firms, namely, (1) Kanti Oil Mills, with 15 per cent share, (2) Shantilal Ramchand Shah with 25 per cent share. Asstt. CED valued the goodwill from the firm mentioned at No. (1) above at Rs. 9,7 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rofits of the two firms. Ld. Deptl. representative urged that in a similar case before IT Appl. Tribunal, Pune Bench, in EDA No. 10/PN/78-79 by order dt. 7th June, 1979, the Bench had rejected similar contention of the accountable person that firm s tax should be deducted. However, this is contradicted by Para 7 of Tribunal s Order, according to which firm s tax had already been deducted by Asstt. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owed because of the different status of different assessee and different personal income of different assessees. He highlighted this by giving examples of different assessee, for example, trust, high income assessees and assessees with no other income. the ld. counsel for the accountable person pointed out that in Estate Duty, we have to compute the value of property which passes on death and that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accept the view in favour of the tax-payer and uphold the order of Appl. Contrl. In allowing deduction of firm s tax for the purpose of computing value of the share of the deceased in the firm. 4. The next grievance in the departmental appeal is regarding Appellate Controller s direction that in respect of firm mentioned at No. (2) above, which is a commission agent in agricultural products, mul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... business as commission agents and was operating in the Agricultural Market Yard and had no special advantage and that more than 200 firms were operating in the said yard and according to him, there was no goodwill attached to any shop as grain was a standard item in which different commission agents were dealing and there was nothing personal nor any reputation of any commission agent nor of place ..... X X X X Extracts X X X X X X X X Extracts X X X X
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