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The High Court of Rajasthan considered a question of law regarding the application of rule 1D of the Wealth-tax Rules. The Income-tax Appellate Tribunal had held the rule as directory, but the Supreme Court ruled it as mandatory in Bharat Hari Singhania v. CWT [1994] 207 ITR 1. The High Court decided in favor of the Department based on the Supreme Court's ruling.
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