1991 (2) TMI 45

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....EDDY C. J. -Under section 27(3) of the Wealth-tax Act, 1957, the Tribunal has stated the following questions : "(1) Whether, on the facts and in the circumstances of the case, rule 1D of the Wealth-tax Rules overrides the provisions of section 24(6) of the Wealth-tax Act ? (2) Whether, on the facts and in the circumstances of the case, it is open to the Revenue to rely upon rule 1D even thou....

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....first question is answered by saying that there is no quest on of rule 1D overriding section 24(6) of the Act. Both provisions operate in their respective distinct fields. Question No. 2 is answered saying that it is open to the Department to rely upon rule 1 D in this reference, notwithstanding the fact that the rule as such does not appear to have been relied upon before the Tribunal. Question N....