9911796707
TMI Blog1991 (4) TMI 58X X X X Extracts X X X X X X X X Extracts X X X X ..... to this court the following question of law for opinion under section 64(1) of the Estate Duty Act, 1953 : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the amount of Rs. 2,27,197 being the value of the annuity of the deceased adopted under the provisions of the Wealth-tax Act should be taken as the property passing under section 7 of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 4,12,260, the case of the accountable person was that it should be the value that was taken in her wealth-tax assessment, i.e., Rs. 2,27,197. Shri Jetley, learned counsel for the Revenue, has referred to the provisions of sections 7 and 40 of the Estate Duty Act. He stated that the deceased's life interest was admittedly property which was deemed to cease or her death within the meaning of s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e principal value of an addition to the property equal to the income to which the interest extended." We see no difficulty in appreciating the submission of Shri Jetley as regards clause (a) of section 40. However, the language used in clause (b) is materially different from that of clause (a). It does not follow from clause (b) that in case the life interest extends to less than the whole income ..... X X X X Extracts X X X X X X X X Extracts X X X X
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