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3. The first objection is to the inclusion of the Compulsory Deposit made by the appellant amounting to Rs. 1,17,840 in his net wealth for this year. The WTO included the said amount of Compulsory Deposit as he was of the view that such amount was not exempt from wealth-tax. On appeal, the CWT (A) relied on the Compulsory Deposit Act which had been retrospectively amended with the introduction of section 7A with effect from 1-4-1975. He pointed out that as per the amended provision, the amount of Compulsory Deposit should be deemed to be a deposit with a banking company. The CWT (A), therefore, directed the WTO to allow exemption on the Compulsory Deposit subject to the ceiling limit under section 5(1A) of the Wealth-tax Act.

4. Before us, the learned counsel for the appellant, urged that the Compulsory Deposit was made by the appellant under a statutory compulsion and was not an annuity purchased by the assessee and that the terms and conditions relating to the Compulsory Deposit precluded the commutation of any portion into a lump sum. He, therefore, contended that the value of this Compulsory Deposit ought to have been excluded from the net wealth of the appellant. The learned Departmental Representative relied on section 7A of the Compulsory Deposit Act which has been inserted in the statute with retrospective effect from 1-4-1975 by the Finance (No. 2) Act, 1980. He submitted that in view of this provision of law, the direction given by the CWT (A) was correct and that the appellant was not entitled to any further relief on this count.