1980 (4) TMI 94

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....untable person the, Income-tax Appellate Tribunal, "B" Bench, Allahabad, has stated the case and has referred the following question for the opinion of this court : "Whether, on the facts and in the circumstances of the case, the Tribunal was correct in including a sum of Rs. 8,000 representing the value of jewellery owned and possessed by the deceased in its estate under the Estate Duty Act, 1....

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....he value of jewellery had been shown as Rs. 8,000 and "nil". As there was no evidence on record to show that the lady had left or had otherwise disposed of the ornaments, the Asst. Controller included Rs. 30,000 in computing the value of the estate left by her. In the appeal, the Appellate Controller accepted the submission made on behalf of the accountable person. He held that whatever jewelle....

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....s passed in the wealth-tax assessments. There was no evidence to show that she had, in any way, disposed of that jewellery or ornaments to anybody prior to her death and that conversion of jewellery into Gold Bonds had been taken into account separately. Learned counsel for the accountable person contended that as it had been shown that the deceased had purchased Gold Bonds, the entire value of....

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....,000 and that there was no material on the record to show that she had disposed of that jewellery during her lifetime. Learned counsel appearing for the accountable person urged that in the W.T. return filed for the year 1965-66, the accountable person had shown the value of the jewellery and ornaments belonging to the deceased as "nil" and that the said returns had been accepted by the WTO. Ac....