Estate duty recovery can reach an accountable person's own assets, subject to the value of estate inherited.

Liability of an accountable person under the Estate Duty Act is a personal liability recoverable from the person's own assets, not confined to the specific property inherited from the deceased. The recovery is nevertheless limited to the value of the estate actually inherited. On that basis, the department was entitled to proceed against other properties of the accountable person for estate duty recovery, and the contention that attachment could be levied only against inherited estate assets was rejected.

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Issues: Whether, for recovery of estate duty, the department could proceed against property of the accountable persons other than the assets inherited from the deceased.

Analysis: The liability of every accountable person under the Estate Duty Act was held to be a personal liability. That liability is not confined to being payable only out of the deceased's estate, though it is limited in extent to the value of the estate actually inherited. On that basis, recovery could not be restricted only to the assets that had come into the hands of the accountable persons as part of the inherited estate.

Conclusion: The contention that attachment could be levied only against inherited estate property was rejected.

Final Conclusion: The department was entitled to proceed against the appellant's other properties for recovery of estate duty, subject to the limitation of liability to the value of the estate inherited, and the appeal was dismissed.

Ratio Decidendi: Liability of an accountable person for estate duty is a personal liability recoverable against his assets, subject only to the monetary limit of the value of the estate inherited from the deceased.

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