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Issues Involved:
1. Valuation of the estate for estate duty purposes. 2. Inclusion of profits from business subsequent to the date of settlement in the estate. 3. Jurisdiction and procedural compliance in the appellate process. 4. Compliance with principles of natural justice. 5. Availability and appropriateness of alternate remedies. Issue-wise Detailed Analysis: 1. Valuation of the estate for estate duty purposes: The petitioner, accountable for estate duty on his deceased father's estate, contested the valuation determined by the first respondent, the Assistant Controller of Estate Duty (CED). The petitioner argued that the properties covered by the settlement deed dated December 29, 1954, should have been valued based on the position as of the date of the deed. The Central Board of Revenue partially allowed the appeal but did not accept the petitioner's valuation method. 2. Inclusion of profits from business subsequent to the date of settlement in the estate: The court addressed two specific questions: - Whether the profits of the business subsequent to the date of settlement, which were reinvested in the business, should be included in the estate. - Whether the Central Board was justified in including the profits and augmented value of the business carried on exclusively by the donees with their own monies and efforts in the estate's value. The court ruled in favor of the petitioner on both questions, indicating that the profits and augmented value due to the donees' efforts should not be included in the estate's value. 3. Jurisdiction and procedural compliance in the appellate process: The petitioner received a notice from the first respondent regarding an enquiry to pass appropriate orders giving effect to the court's judgment. The first respondent assigned the value given in the settlement document to the properties. The petitioner's appeals to the third and second respondents were dismissed on jurisdictional grounds, as the amended Estate Duty Act did not allow for such appeals. The court upheld the dismissal of these appeals, affirming that the petitioner could not avail of the appellate forums before the Appellate Controller and the Appellate Tribunal. 4. Compliance with principles of natural justice: The petitioner argued that the fourth respondent failed to exercise jurisdiction under section 64(7) of the principal Act by not disposing of the appeal conformably to the court's judgment. The purported remand order by the fourth respondent was passed without notice or an opportunity to be heard, rendering it null and void. The court agreed, emphasizing that the Board should have given the petitioner a chance to be heard and that the remand deprived him of his right to arbitration for valuation disputes, which was a significant procedural safeguard. 5. Availability and appropriateness of alternate remedies: The revenue's counsel argued that the petitioner had delayed seeking relief and had participated in proceedings without demur, thus acquiescing to the process. The court acknowledged that while typically it refrains from granting relief in cases of delay or where alternate remedies exist, it may exercise its jurisdiction under Article 226 of the Constitution in exceptional circumstances to further the ends of justice. The court determined that the purported remand order was a nullity due to the lack of adherence to natural justice principles, and thus the petitioner's appeal remained undisposed. Conclusion: The court quashed the fourth respondent's order and directed the fourth respondent to dispose of the petitioner's appeal in accordance with the court's earlier judgment, ensuring compliance with legal procedures and principles of natural justice. The court emphasized that the petitioner should be given a reasonable opportunity to be heard, and no prejudice would be caused to the revenue by adopting this course. The writ petition was allowed, and the fourth respondent was instructed to proceed accordingly.
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