In so far as 8 appeals arising from the assessment orders passed under the Income Tax Act, 1961 are companycerned, they relate to assessment years 1984 85, 1985 86, 1986 87, 1987 88, 1988 89, 1989 90, 1990 91 and 1991 92.
Of the 9 Wealth Tax appeals, one appeal relates to protective assessment for 18 assessment years, i.e, 1970 71 to 1976 77, 1978 79 to 1979 80, 1981 82 to 1989 90.
The remaining 8 Wealth Tax appeals relate to assessment years 1970 71, 1971 72, 1972 73, 1973 74, 1974 75, 1975 76, 1976 77 and 1978 79.
This is a group of 17 Appeals 8 arising from the Income Tax Act, 1961 and 9 arising from the Wealth Tax Act, 1957.
If so, clause 4 sprang into operation whereunder the entire income under the settlements flowed to the settlor during his lifetime and on his death, to his elder son, the appellant herein.
i the assessee has number admitted having received the income, the assessee has number received the said income and iii the assessee has number shown as taxable income in the returns of all the years under appeal.
For the assessment years under companysideration in these appeals, the High Court numbered the following distinguishing features, viz.,
