9911796707
TMI Blog1990 (11) TMI 134X X X X Extracts X X X X X X X X Extracts X X X X ..... st the notice issued by the Assistant Controller, Estate Duty, under section 59 of the Estate Duty Act proposing to reopen the assessment relating to the estate of the deceased Brij Lal Gupta, father of the petitioner. The death had occurred on February 7, 1976. The petitioner filed return as an accountable person and an assessment was made under section 58(3) of the Act on March 19, 1977. It is, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ought to be revised. After receiving the impugned notice, the petitioner submitted a letter dated March 18, 1980, stating that, from the letter of the Assistant Valuation Officer dated September 27, 1979, it appears that the assessment is reopened on the basis of the observations made by the Inspecting Assistant Commissioner (Audit), Lucknow, and hence, a copy of the said observations may be suppl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ht to be reopened on the basis of the observations made by the Inspecting Assistant Commissioner (Audit), Lucknow, cannot be said to be without force. Section 59 of the Estate Duty Act is in pari materia with section 147 of the Income-tax Act, as it stood prior to the 1989 amendment. Under section 147, it has been held by the Supreme Court that the report of the Audit Officer cannot be treated a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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