9911796707
TMI Blog1992 (4) TMI 33X X X X Extracts X X X X X X X X Extracts X X X X ..... t years 1972-73, 1973-74, 1974-75 and 1975-76. The only question of law which has fallen for our consideration is as follows : " Whether, on the facts and circumstances of the case, the intangible additions made in income-tax proceedings could be treated as the assets of the assessee for the purpose of wealth-tax assessment in the light of the provisions of sections 2(e) and 2(m) of Wealth-tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er of the Wealth-tax Officer, the assessee preferred an appeal before the Appellate Assistant Commissioner but could not get any relief. Accordingly, he preferred a second appeal to the Tribunal. The Tribunal, following its earlier order for the assessment years 1968-69 to 1971-72, deleted the addition.This court, pursuant to a reference made at the instance of the Revenue in respect of those year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [1990] 182 ITR 230. Following these decisions, we respectfully agree with the view taken therein and answer the question referred to this court in the affirmative and against the assessee. Before parting with the judgment, we may notice here that Mr. K. N. Jain, appearing for the assessee, has submitted that the intangible additions made under the income-tax proceedings during the assessment ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the assessee are found to be correct, then, keeping in view the requirement of justice, the Tribunal will give due consideration to this aspect of the matter and pass appropriate orders in accordance with law. In the facts and circumstances of the case, there will be no order as to costs. Let a copy of the judgment be forwarded to the Assistant Registrar, Income-tax Appellate Tribunal, Patn ..... X X X X Extracts X X X X X X X X Extracts X X X X
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