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1989 (12) TMI 125 - AT - Income TaxExtract: .......iness asset. Though this is not conclusive of determining whether was the value thereof would partake the nature of income, this is indicative of the primary use of the article gifted, which cannot be ignored in the context. We accordingly uphold the findings of the authorities below in this regard. 23. In the result, the appeal is allowed in part.
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