(1.) THE Income-tax Appellate Tribunal has referred the following question of law to this court for opinion under Section 64 (1) of the Estate Duty Act, 1953, hereinafter called the Act.
(2.) THE facts as found by the Tribunal have been summarised in para. 3 of the statement of the case as under :
(3.) AFTER the (Jeath of Udham Singh, the Assistant Controller of Estate Duty made an assessment of his three sons as accountable persons and charged his entire property to estate duty.