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1971 (7) TMI 135

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....for decision in these appeals is whether the goods in transit from England to India belonging to a non-resident assessee can be considered as wealth of the assessee during the relevant valuation dates. The relevant assessment years are 1957-58, 1958-59 and 1959-60. The assessee is admittedly a non-resident company. It is said that during the relevant valuation dates some goods belonging to the a....

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.... wherever located, belonging to the assessee on the valuation date, including assets required to be included in his net wealth as on that date under this Act, is in excess of the aggregate value of all the debts owed by the assessee on the valuation date other than . . . . " (The remaining portion is not relevant for our purposes). If these provisions had stood by themselves there would have bee....

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....company. Therefore, in computing its net wealth the restrictions placed by section 6 will have to be taken into consideration. Quite clearly, the High Seas cannot be considered as a part of India in the absence of anything in the Act making it a part of India. Therefore, prima facie, we must proceed on the basis that the goods with which we are concerned in this case were located outside India o....