1981 (8) TMI 154

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....res have been granted exemption in the assessee's assessments upto the asst. yr. 1972-73 under s. 5(1)(xx). The WTO in making the assessments had denied exemption on the share holdings of the assessees on the ground that they fall under the category of shares mentioned under s. 5(1)(xx) and the five years period of exemption has expired. 2. Before the AAC in appeal against the WTO's orders the assessees contented that s. 5(1)(Xx) given exemption without any monetary limits to the equity shares in industrial companies forming part of the initial issue for the first five assessment years and thereafter the assessee is entitled to exemption upto the limit of Rs. 1,50,000 under s. 5(1)(xxiii) r/w s. 5(1A). The AAC rejected this contention poin....

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....), (xxiii), (xxiv), (xxv), (xxvi), (xxvii), (xxviii), (xxix), (xxxi), and (xxxii) (not being deposits under the Post Office Savings Bank (Cumulative Time Deposits) Rules, 1959 to the extent the value thereof exceeds, in the aggregate, a sum of one hundred and fifty thousand rupees..." Sub-cl. (xxiii) and s. 5 (1A) were inserted by s. 26 of the Finance Act, 1970 w.e.f. 1st April, 1971. The memo explaining all the provisions of the Finance Bill, 1970 states regarding the above amendment : in order to widen the area of investments in financial assets qualifying for exemption from Wealth-tax it is proposed to extend the exemption from Wealth-tax in the following categories of investments: (b) Shares in Indian Companies......(75 ITR St. 101). ....