Valuation challenge under the Estate Duty Act was appealable where the accountable person objected to the Controller's share valuation.

An appeal was maintainable under the Estate Duty Act, 1953 where the accountable person objected to the valuation of shares made by the Controller. Section 62(1)(a) was read as permitting appellate review of a valuation challenge arising from an order under section 61, including a rectification-based valuation determination. The Tribunal's view that such an appeal could not be rejected in limine was upheld, and the appellate question was answered in the affirmative in favour of the accountable person.

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Issues: Whether an appeal lay to the Appellate Controller against an order made under section 61 of the Estate Duty Act, 1953 in relation to the valuation of shares.

Analysis: The dispute concerned the valuation of shares in the estate duty assessment. The Court read section 62(1)(a) of the Estate Duty Act, 1953 as permitting an appeal where the person objected to a valuation made by the Controller. Since the challenge was directed against the valuation determined under the rectification order, the matter fell within the appellate provision. The Tribunal's view that the appeal was entertainable and could not be rejected in limine was upheld.

Conclusion: An appeal was maintainable against the order made under section 61 of the Estate Duty Act, 1953, and the question was answered in the affirmative, in favour of the accountable person.

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