(1.) THE Income Tax Appellate Tribunal, Chandigarh Bench, has referred the following question of law for our opinion :
(2.) SHRI D. P. Malhotra was the Chief Engineer in the State of Jammu & Kashmir. He died on 7th February, 1966, in a plane crash near Banihal. On his death, his widow and sons were given Rs. 42,000 by the Indian Airlines Corporation (the carriers). The amount was subjected to estate duty by the Assistant Controller, Estate Duty, Julhmdur, who observed :
(3.) THE Appellate Controller allowed the appeal and observed as follows: