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1985 (1) TMI 113 - ITAT COCHINExtract: .......did not mention that he is assessing those fixed deposits as the assessee s wealth under s. 4(1) (a) (i) of the WT Act, 1957. So in the facts and circumstances of the case, we hold that the GTO is not justified in treating Rs. 84,330 and Rs. 25,000 as gifts for the asst. yrs. 1977-78 and 1977-78 respectively. In the result, the appeals are allowed.
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