1982 (2) TMI 137

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....d order dated 29-11-1980 of the Commissioner (Appeals). By the said order, the Commissioner disposed of appeals relating to the assessment years 1965-66 to 1974-75. We are concerned with only appeals relating to five assessment years. 2. 1965-66 to 1969-70 are the assessment years concerned. 31st March immediately preceding each assessment year is the corresponding valuation date. The assessee ....

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....e excluded if the assessee fulfils the conditions laid down in the Voluntary Disclosure Scheme, 1975. 4. The assessee went in appeal to the Commissioner (Appeals) and raised three contentions as enumerated in the AAC's order. Third contention read "he (the IAC) has not pointed out any specific ground or reason for this inclusion." The AAC taking into consideration the contentions of the assesse....

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....anation : Where a declaration under sub-section (1) of section 3 is made by a firm, the assets referred to in clause (i) or, as the case may be, the amount referred to in clause (ii) shall not be taken into account in computing the net wealth of any partner of the firm or, as the case may be, in determining the value of the interest of any partner in the firm." 6. The said Explanation leaves no....