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TMI Blog1989 (8) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... ylhet town in Sylhet district of undivided Bengal in pre-partition days. Baikuntha Gupta, by a gift deed executed on July 2, 1915, endowed Rs. 2,90,000 and appointed Messrs. B. C. Gupta and Sons, the manager of the Star Tea Estate as trustee of the two idols. After the partition of India, Sylhet became part of East Pakistan, now Bangladesh. The two idols are in India in the Cachar District of As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amkhya School of thought. The instant reference is under the Wealth-tax Act, 1957. The Wealth-tax Officer, for the assessment year 1964-65, assessed the two idols as one unit. Thereupon, the Commissioner of Wealth-tax, on February 7, 1975, set aside the orders and directed the idols to be assessed as two units of assessment. In the subsequent proceedings relevant to 1966-67, 1967-68 and 1969-70 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are not individuals and section 3 does not apply in the case of deity and, therefore, the Wealth-tax Act does not apply to a deity, is not untenable in law ? There was an overdrawn controversy under the Indian Income-tax Act, 1922, whether an idol is a person and also an individual. The controversy is now set at rest by Parliament in the definition clause (31) of section 2 of the 1961 Act to st ..... X X X X Extracts X X X X X X X X Extracts X X X X
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