https://www.taxtmi.com/caselaws?id=16151 For limitation under the Estate Duty Act, proceedings for levy of estate duty under section 59 commence on issuance of the notice, not on its service. Section 73A(a) bars first assessment proceedings only if commenced after five years from the date of death, and the Court construed that bar strictly but found no requirement that service must also occur within that period. A notice issued within five years was sufficient to validly start proceedings, so non-service did not defeat initiation for limitation purposes. The referred question was answered in favour of the Department. en-us Fri, 07 Feb 1997 00:00:00 +0530 Tue, 01 Sep 2009 13:50:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16151 For limitation under the Estate Duty Act, proceedings for levy of estate duty under section 59 commence on issuance of the notice, not on its service. Section 73A(a) bars first assessment proceedings only if commenced after five years from the date of death, and the Court construed that bar strictly but found no requirement that service must also occur within that period. A notice issued within five years was sufficient to validly start proceedings, so non-service did not defeat initiation for limitation purposes. The referred question was answered in favour of the Department. Case-Laws Income Tax Fri, 07 Feb 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16151