Quick succession relief applies to traceable sale proceeds and investments when inherited property changes form.

Quick succession relief under the Estate Duty Act was interpreted broadly by reading "same property" with the statutory definition of property, which covers proceeds of sale, money or investments representing those proceeds, and property converted from one form into another. The Court held that relief is not limited to the identical physical asset remaining unchanged at the second death. Where sale proceeds can be clearly traced to property earlier subjected to estate duty, the concession cannot be denied merely because the property has changed form. Relief was therefore admissible on the sale proceeds and related investments, and the accountable person was entitled to full relief.

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Issues: Whether quick succession relief under section 31 of the Estate Duty Act, 1953 was available in respect of sale proceeds and investments traceable to immovable property inherited by the deceased within five years of the first death.

Analysis: The expression "same property" in section 31 was read with the statutory definition of "property" in section 2(15), which includes movable and immovable property, the proceeds of sale thereof, money or investments representing such proceeds, and property converted from one species into another. On that basis, the Court held that the relief is not confined to the identical physical asset remaining unchanged at the second death. Where the sale proceeds are clearly identifiable as originating from the property earlier subjected to estate duty, the concession cannot be denied merely because the form of the property has changed. The restriction imposed by the revenue authorities was therefore unsupported.

Conclusion: Quick succession relief was held admissible on the sale proceeds and related investments, and the accountable person was entitled to the relief in full.

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