COMMISSIONER OF INCOME TAX Vs. BADHURANI DEEPINDER KAUR

JUDGEMENT

(1.) THIS is an appeal under s. 27A of the WT Act, 1957 (for short, "the Act") for determination of the following questions of law :

(2.) WE have heard Dr. N.L. Sharda and perused the orders of the assessment passed by the WTO, Faridkot, in relation to the asst. yrs. 1969-70 to 1980-81, the appellate order passed by the CIT(A) and the orders passed by the Income-tax Appellate Tribunal, Amritsar (for short "the Tribunal"). While dealing with the question whether the flat in Reviera Apartment, Okhla Industrial Estate, New Delhi, belonging to the assessee could be treated as part of his wealth for the purposes of the Act, the Tribunal referred to the factum of payment of Rs. 1 lakh by the assessee on 25th Nov., 1968, letters, dt. 5th Nov., 1968, 25th Nov., 1968 and 26th Nov., 1971, sent by Reviera Apartments (P) Ltd., New Delhi, and observed as under :