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1984 (2) TMI 130 - ITAT BOMBAY-DExtract: .......or reasons given above, we uphold the claim made on behalf of the assessee to the effect that he was not citizen of India and non-resident in India in the year ending on the relevant valuation date and, as such, rule 3 of Part II of Schedule I applied to him. The order of the AAC must be upheld. 21. In the result, the appeal fails and is dismissed.
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