Relief from estate duty: statutory duty to allow gift tax relief is not barred by the rectification limitation period. The Controller of Estate Duty has a statutory duty to allow relief under section 50A for gift-tax paid, and the rectification time-limit for estate duty assessments does not apply to that statutory obligation; relief for gift-tax cannot be denied solely because the limitation for rectification has expired.
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Provisions expressly mentioned in the judgment/order text.
Relief from estate duty: statutory duty to allow gift tax relief is not barred by the rectification limitation period.
The Controller of Estate Duty has a statutory duty to allow relief under section 50A for gift-tax paid, and the rectification time-limit for estate duty assessments does not apply to that statutory obligation; relief for gift-tax cannot be denied solely because the limitation for rectification has expired.
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