Limitation on estate duty proceedings: commencement bars differ from completion, affecting assessments on late voluntary returns. The Board advises that Section 73A bars only the commencement of estate duty proceedings after the limitation period but does not prevent completion of proceedings lawfully commenced; assessments based on voluntary returns filed after the five year period are not automatically time barred if proceedings began in time. The Board recommends contesting appellate cancellations on limitation grounds and directing income tax officers to promptly notify the Assistant Controller of Estate Duty of deaths to enable timely initiation of proceedings.
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Provisions expressly mentioned in the judgment/order text.
Limitation on estate duty proceedings: commencement bars differ from completion, affecting assessments on late voluntary returns.
The Board advises that Section 73A bars only the commencement of estate duty proceedings after the limitation period but does not prevent completion of proceedings lawfully commenced; assessments based on voluntary returns filed after the five year period are not automatically time barred if proceedings began in time. The Board recommends contesting appellate cancellations on limitation grounds and directing income tax officers to promptly notify the Assistant Controller of Estate Duty of deaths to enable timely initiation of proceedings.
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