TMI Blog1997 (1) TMI 39X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 64(3) of the Estate Duty Act, 1953, seeking a direction to the Income-tax Appellate Tribunal to refer the following two questions to this High Court for opinion : "1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the notice under section 59(a) of the Estate Duty Act, 1953, expressed in the joint names of 'Jatind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assistant Controller issued further notices. Jatinder Kumar appeared on November 26, 1975, and claimed that the proceedings have become time-barred. This plea was not accepted on the ground that the proceedings had been validly commenced within the limitation period of 5 years from the date of death of the deceased. Thereafter, the accountable person failed to appear and an assessment was made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elating to a fact and, therefore, in our opinion, the controversy does not give rise to a question of law. In the result, the application, filed by the Revenue, is rejected on the ground that no referable question of law arises from the order of the Tribunal and the questions, sought to be referred, do not give rise to a question of law to be answered by this court. - - TaxTMI - TMITa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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