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Issues:
1. Interpretation of the period of limitation under section 73A of the Estate Duty Act. 2. Determining the point of time when proceedings under section 59(a) are deemed to have commenced. Analysis: The judgment delivered by the High Court of Punjab and Haryana pertained to a petition filed under section 64(3) of the Estate Duty Act, 1953, requesting the Income-tax Appellate Tribunal to refer questions of law to the High Court for its opinion. The case involved the accountable persons of a deceased individual challenging the dutiable estate declaration and penalty proceedings initiated by the Assistant Controller of Estate Duty. The Appellate Controller upheld the plea that reasonable opportunity was not granted, remanding the case for a fresh order. Subsequently, the Appellate Tribunal accepted the contention that the proceedings were time-barred, emphasizing that the proceedings under section 59 commence only upon service of notice to the accountable persons, not mere issuance. The High Court analyzed the timeline of events, noting discrepancies in the issuance and service of notices under section 59(a) to the accountable persons. The crucial legal issue revolved around the point of time when proceedings under section 59(a) are considered to have commenced, impacting the applicability of the limitation period under section 73A of the Act. The court identified a key question of law regarding the initiation of the limitation period from the date of notice issuance or service to the accountable person, along with the correctness of the Tribunal's decision in deeming the notice as time-barred and setting aside the Assistant Controller's assessment order. Consequently, the High Court allowed the petition, directing the Tribunal to refer the pertinent legal question to the court for consideration, emphasizing the importance of clarifying the commencement of the limitation period under section 73A and the validity of the Tribunal's decision in the estate duty assessment matter.
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