BHARATI SAPRU,J. - (1.) HEARD Sri Shambhu Chopra appearing on behalf of the Department and Sri S.D. Singh appearing on behalf of assessee.
(2.) THE present wealth -tax appeal has been filed under Section 27A of the WT Act, 1957 against the order dt. 28th May, 1999, passed by Tribunal, Allahabad Bench, Allahabad in WTA No. 110/All/1996 for the asst. yr. 1989 -90. The relief sought in the present appeal is that the order dt. 28th May, 1999, passed by the Tribunal Allahabad in the WTA No. 110 of 1996 for the asst. yr. 1989 -90 in the case of WTO v. Smt. Shakuntala Devi Dalmia, Kanpur, be set aside and the impugned order of penalty made against the assessee under Section 18(l)(c) imposed by the WTO's order dt. 23rd March, 1993 be restored.
(3.) THE following two substantial questions of law have been called for in the present case: 1. Whether on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that neither Expln. 2 nor Expln. 4 to Section 18(l)(c) of the WT Act, 1957 was applicable to this case ? 2. Whether on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the explanation offered by the assessee was sufficient to rebut the presumption for concealing the particulars in relation to the value of the immovable property bearing No. 87/110(3), Kalpi Road, Kanpur, or for furnishing inaccurate particulars of the asset ? ;