CONTROLLER OF ESTATE DUTY Vs. SINGAPORIA K P

JUDGEMENT

(1.) THERE is only one question of law involved in this reference. The question reads thus :

(2.) IT is fairly stated by Shri Jetley, learned counsel for the Department, that there are many decisions including the latest one of the Supreme Court in the case of CWT vs. K. S. N. Bhatt (1984) 145 ITR 1 (SC), wherein the context of wealth-tax proceedings, it was held that liability towards wealth-tax, income-tax and gift-tax which crystallise on the relevant valuation date are to be deducted from the wealth even though the assessment orders are finalised after the valuation date. IT was, however, pointed out that there was no direct decision under the ED Act on the question.