Estate Duty - Interpretation of Sec.73A - Applicability of penalty.

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..... ment of Estate Duty proceedings by revenue authorities beyond the statutory period of 5 years but if the proceedings have commenced otherwise, it does not operate as a bar to their completion. In other words there is no bar to the completion of assessment on the basis of a voluntary return filed beyond the statutory period of 5 years. It was further advised that in a case where the assessment is c .....

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..... late filing of the return can be initiated and the penalty levied in pursuance of the same. This is so because:- (i) Section 73A only bars the commencement of the proceedings by the revenue authorities. (ii) The provisions for filing a return are contained in section 53 and section 56 of the ED Act. Thus the return filed voluntarily even after the expiry of the said period of the limitation pres .....

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