(1.) THIS reference, under s. 64(1) of the ED Act, has been made in circumstances hereinafter stated. One Bhupendra Nath Mukherjee died intestate on 27th Dec., 1955. During his life, on 16th June, 1916, Bhupendra executed a deed of gift, in the Bengali language, in favour of his eldest son, Panchanan Mukhopadhyaya. The English translation of the material portion of the deed reads as follows :