1978 (8) TMI 103

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.... share in an immovable property taken at the price for which the property was ultimately sold, the assessee's wealth is not liable to wealth-tax, and that the assessee filed her wealth-tax returns for all these years voluntarily on 31st day of March, 1970. The assessments were, however, completed computing the assessee's wealth which was taxable and the WTO has recorded a finding in the orders of assessment that penalty proceedings of s. 18(1) (a) were attracted. 2. In reply to show cause memo the assessee stated that she was old and illiterate, that the rental income from the property was much less and that her wealth would not have been taxable even ifs the property was valued by applying multiple of 20 to the net rental income from th....

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....er the WT Act. 5. The counsel for the assessee, on the other hand, strongly relied on the orders of the AAC. In particular he laid great emphasis on the fact that the assessee was old and illiterate; that she was not represented by any Counsel in the income-tax proceedings; that she became liable to wealth-tax for the first time and that the wealth-tax returns were filed voluntarily. For this purpose the learned Counsel invited our attention to a Press Note dated 2nd June, 1969 issued by the Ministry of Finance (Deptt. of Revenue & Insurance) (available at Taxman's CBDT Circulars Vol. 1-1977 Page 922 Cir No. 552) to show that where a return making full disclosure of the net wealth is furnished voluntarily before the issue of the Notice a....