PRABHAVATI B SOLANKI Vs. COMMISSIONER OF WEALTH TAX

JUDGEMENT

(1.) The following two questions of law arising out of tribunal's order dated 11.6.1981 have been referred to this court for its opinion by the Income Tax Appellate Tribunal, Ahmedabad Bench 'A' at the instance of the assessee:-

(2.) Prior to 1.4.1975, Wealth-tax Act provided no limitation for completion of assessments under it. By insertion of sec. 17A by the Taxation Laws (Amendment) Act, 1975 with effect from 1.1.1976 for the first time period of limitation for completion of assessment was provided. For the period prior to 1.4.1975 the section as it originally was inserted provided that no order of assessment shall be made under sec. 16 at anytime after the expiration of a period of -

(3.) The tribunal, while examining this issue, noticed that there are three stages under the scheme of the Act before the liability of the assessee is communicated to assessee,