CONTROLLER OF ESTATE DUTY Vs. SARAF

JUDGEMENT

(1.) BY a petition made under Section 64(1) of the Estate Duty Act, 1953, the Revenue sought reference of as many as five questions. The Income-tax Appellate Tribunal referred only questions Nos. 1 and 5 for the opinion of this court and declined to refer the remaining questions. Question No. 4 in the application made under Section 64(1) was as follows :

(2.) LEARNED senior standing counsel presses before us only the abovementioned question No. 4 which, in our opinion, is a question of law. We, therefore, direct the Income-tax Appellate Tribunal to draw up a statement of the case and refer the abovementioned question No. 4 only for the opinion of this court.