1992 (8) TMI 98

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....ain amount of money from a foreign country to India. He had claimed inter alia that the interest accrued thereon was exempt from wealth-tax under section 5(1)(xxxiii). The Wealth-tax Officer while granting him the exemption on the principal amount did not give that exemption in respect of the accrued interest. The Dy. Commissioner of Wealth-tax (Appeals), however, following the decision of the Tri....

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....h the efflux of time then those entire assets would be eligible for exemption. Therefore, according to the Tribunal, there was no reason why the position would be different where moneys brought in had increased by efflux of time on account of the interest earnings thereon. 2. The material part of section 5(1)(xxxiii) is as follows :--- " in the case of an assessee, being a person of Indian o....

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....ch is so substituted which would be exempted under section 5(1)(xxxiii), the expression "out of" is of a common use. Thus, a shirt is made out of a piece of cloth, an item of jewellery is made out of a given quantity of precious metal, etc. If some decoration is added to the shirt or gems are added to the item of jewellery they are not out of the piece of cloth or the precious metal. In making the....