TMI Blog1986 (6) TMI 51X X X X Extracts X X X X X X X X Extracts X X X X ..... issued under s. 16(2) of the WT Act it had been contended on behalf of the assessee that the value of the house property under s. 7(4) of the Act should be taken at Rs. 2,17,400 as was taken during the asst. yr. 1971-72 and not as per the valuation report at Rs. 9,34,650. The assessing officer had observed that the assessee was a non-resident during the year under consideration and the house in qu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee was a Non-resident and had never occupied the house in question and as such s. 7(4) of the WT Act is not applicable. He has also contended that the AAC has applied the provisions of law and the decisions relied on by him are not at all applicable to the facts of the present case. He has also invited our attention towards s. 6(1) (b) of the IT Act and has submitted that for being a residen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t has been submitted on assessee's behalf that he is entitled to the benefit of s. 7(4) of the Act. 4. We have given our anxious consideration to the submissions advanced before us. To our mind the words "exclusively used by him for residential purposes through out the period of 12 months immediately preceding the valuation date" should be interpreted pragmatically fairly and reasonable and not ..... X X X X Extracts X X X X X X X X Extracts X X X X
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