TMI Blog1997 (1) TMI 13X X X X Extracts X X X X X X X X Extracts X X X X ..... section 64(3) of the Estate Duty Act, 1953 (hereinafter referred to as "the Act"), for directing the Income-tax Appellate Tribunal, Chandigarh Bench, to make a reference of the questions of law framed by the petitioner to the High Court for its opinion: In response to the notice issued by the Assistant Controller of Estate Duty under section 59 of the Act, Shri Gurbachan Singh and Shri Jaswant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... han Singh that reasonable opportunity was not given to him. Accordingly, it remanded the case to the Assistant Controller to pass a fresh order after giving reasonable opportunity to the accountable persons. The order of the appellate authority was challenged by Shri Gurbachan Singh before the Appellate Tribunal. Vide its order dated March 3, 1983, the Tribunal accepted the contention raised on be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a) was issued on March 25, 1977, to Gurbachan Singh. Notices to other two accountable persons were issued on July 11, 1977. The appellate authority, before whom the respondent Gurbachan Singh had filed appeal against the order of the Assistant Controller, rejected his plea that the initiation of proceedings was barred by the period of limitation prescribed under section 73A of the Act. However, th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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