(1.) This is a reference by the Income Tax Appellate Tribunal, Madras Bench, under S.64(1) of the Estate Duty Act, 1953. The question referred is:
(2.) The question arises out of the order of the Appellate Tribunal in E. D. A. Nos. 12 and 18 of 1962-63 dated the 28th July 1964. The estates concerned are those of Smt. Jayalakshmi Devi and Shri Madhava Rajah of Kollengode. The former died on the 6th March 1954; and the latter, on the 9th May 1955.
(3.) The statement of the case deals with the order of the Appellate Tribunal in so far as it relates to this reference as follows: