COMMISSIONER OF WEALTH TAX Vs. UTTAM CHAND JAIN

JUDGEMENT

(1.) ON being moved by the Revenue, Income Tax Appellate Tribunal, Delhi Bench 'D' (for short Tribunal), has referred the following question under Section 27(1) of the Wealth -tax Act, 1957 (for short the Act), for opinion of this Court :

(2.) FACTUAL position in a nut -shell is as follows :

(3.) MAIN point for adjudication is whether a point which was not subject matter of appeal can be said to have been decided and the doctrine of merger would apply also in respect of such an issue.