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TMI Blog2000 (11) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... e against whom recovery proceedings were initiated under section 29 of the Gift-tax Act, 1958 (in short "the Act"). The assessment years in question are 1966-67 and 1973-74. The assessment was made by the assessing authority against the legal representatives of the donor from whom the donees have received gifts. Without taking any proceedings against those legal representatives of the donor for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s, revisions and references. Section 22 of the Act is the provision which provides for appeals to the Deputy Commissioner of Appeals from the orders of the Assessing Officer. Section 23 of the Act deals with appeals to the Appellate Tribunal. Section 24 deals with the powers of the Commissioner to revise the orders of subordinate authorities, Section 25 provides for an appeal to the Tribunal from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of enhancement made by the Chief Commissioner. The marked difference in the expression used in these provisions indicates the legislative intention to confer the right of appeal under section 22 to a larger class than the assessee, while the other provisions earlier referred to limit the right, given under those provisions only to assessees. The term "any person" used in section 22(1) of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 33 read with section 221(1) of the Income-tax Act; and persons objecting to an order of the Assessing Officer under section 34, to file appeals. While some of the clauses of section 22(1) come to the rescue only of assessees like section 22(1)(d), (e) and (g), the other clauses are applicable to non-assessee as well. Section 22(1)(b) of the Act enables a person to object to the amount of gift ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovided under the Act to decide as to whether the power under section 29 of the Act had been properly exercised. Having regard to the scheme of the Act, the language employed in section 22 which is in contrast to the narrower language employed in the other provisions of Chapter VI with regard to persons entitled to file appeals or revisions it must be held that the term "person" in section 22(1) w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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