(1.) THIS reference is made under Sub Sub-sectionsection (1) of Section 64 of the Estate Duty Act, 1953. The two questions referred are :
(2.) RAM Kumar Sovasaria died at the ripe age of 82 on August 19, 1971, at Tinsukia. This reference relates to his estate. In this case the accountable person is Murarilal Sovasaria.
(3.) THE accountable person and the Revenue both filed appeals before the Income Sub-sectiontax Appellate Tribunal at Gauhati. THE Tribunal confirmed the decision of the appellate authority as respects the decision of Rs. 1,03,666 and deleted the addition of Rs. 9,450 relating to goodwill. Thus, the appeal of the accountable person was allowed. THE appeal filed by the Revenue was dismissed. Hence, the two questions in this court.