Service of notice under Estate Duty Act held to raise no referable question of law where dispute was factual

A dispute under the Estate Duty Act concerned whether service of notice on the accountable persons, including a joint notice in their names, raised a referable question of law. The High Court noted that the controversy depended on the factual matrix of notice service and whether the assessment failed for want of service. Because the Tribunal's order did not disclose a pure question of law, the requirement for reference was not met under section 64(3) of the Estate Duty Act, 1953. No referable question of law arose, so the request for reference was rejected.

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Issues: Whether the dispute regarding service of notice on the accountable persons under the Estate Duty Act, 1953 gave rise to a referable question of law for opinion of the High Court.

Analysis: The controversy turned on whether a joint notice issued in the names of the accountable persons was valid service on one of them and whether the assessment failed for want of service. The determination depended on the factual matrix concerning service of notice and the record did not disclose a pure question of law arising from the Tribunal's order. As the issue was essentially factual, it did not satisfy the requirement for reference under section 64(3) of the Estate Duty Act, 1953.

Conclusion: No referable question of law arose, and the request for reference was rejected.

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