ITAT directs reassessment of copper coins exemption, allows deduction of tax liabilities and land/building tax.

The ITAT partly allowed the appeals, directing the assessee to claim exemption of the value of copper coins under s. 5(1)(xii) afresh. The exemption under s. 5(1)(iv) for the years 1970-71 and 1971-72 was allowed subject to verification. The ITAT also permitted the deduction of taxation liabilities and land/building tax from the total wealth for the years 1973-74 to 1977-78, emphasizing the need for thorough examination and verification of the liabilities. The decision of the CWT (Appeals) in previous years would guide the current cases.

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Issues:
1. Exemption of the value of copper coins under s. 5(1)(viii) of the WT Act.
2. Claim for exemption under s. 5(1)(iv) of the WT Act for the years 1970-71 and 1971-72.
3. Allowance of taxation liabilities and land and building tax liability from the total wealth for the years 1973-74 to 1977-78.

Analysis:
1. The appeals involved a common ground regarding the assessee's claim for exemption of the value of copper coins under s. 5(1)(viii) of the WT Act. The CWT (Appeals) had granted the exemption under s. 5(1)(xii), which was challenged by the Revenue. The ITAT directed that the assessee could claim the exemption under s. 5(1)(xii) afresh, and the CWT (Appeals) would consider it after giving an opportunity to the WTO. The decision of the CWT (Appeals) in previous years would govern the decision in the current cases as well.

2. Another issue was the assessee's claim for exemption under s. 5(1)(iv) of the WT Act for the years 1970-71 and 1971-72. The exemption had not been claimed before the WTO or in the original grounds of appeal. The CWT (Appeals) directed that this exemption should be allowed after verifying the facts for the years 1964-65 to 1969-70. The ITAT directed that the decision of the CWT (Appeals) during these years would be subject to verification by the WTO based on his order in relation to the earlier years.

3. The third issue related to the allowance of taxation liabilities and land and building tax liability from the total wealth for the years 1973-74 to 1977-78. The ITAT noted discrepancies in the treatment of liabilities by the WTO and directed a thorough examination of the exact liabilities of the assessee on the relevant valuation dates. The ITAT allowed the liabilities claimed by the assessee, emphasizing the statutory nature of the liabilities and the need for verification of the amounts and payment dates.

In conclusion, the ITAT partly allowed the appeals for statistical purposes, addressing the various issues raised by the parties and providing directions for further examination and verification where necessary.

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