1978 (9) TMI 96

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....ribunal to refer to the High Court the following question, said to be a question of law, arising out of the order of the Tribunal in EDA No. 65 (Mds) of 1976 77. dt. 31st Jan., 1978. "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was correct in holding that the provisions of s. 33 (1) (o) of the ED Act would apply in respect of the gifts included in the ED a....

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....iting the accounts of the donees on the some dates. 3. The Department went in appeal to the Appellate Tribunal. The Department relied on the decision in the Madras High Court in the case of S.M.N Mahadevan Chettier, Whereas the assessee's counsel, Sri R. Venkataraman, contended that the entries having been made by the partnership and evidenced as such, it will be an actionable claim and, theref....