https://www.taxtmi.com/caselaws?id=40158 Section 73A of the Estate Duty Act was construed as an absolute bar on proceedings for levy of estate duty after the prescribed five-year period, including proceedings connected with grant of representation or a succession certificate under section 56. The phrase "under this Act" was read broadly, and section 59 was treated as reinforcing the statutory time-bar rather than creating an exception. A literal reading of section 56 that would still require a Controller's certificate after limitation had expired was rejected as inconsistent with the scheme and object of the Act. The harmonious construction applied preserved the bar and denied any override by procedural requirements. en-us Tue, 12 May 1992 00:00:00 +0530 Fri, 18 Jul 2014 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40158 Section 73A of the Estate Duty Act was construed as an absolute bar on proceedings for levy of estate duty after the prescribed five-year period, including proceedings connected with grant of representation or a succession certificate under section 56. The phrase "under this Act" was read broadly, and section 59 was treated as reinforcing the statutory time-bar rather than creating an exception. A literal reading of section 56 that would still require a Controller's certificate after limitation had expired was rejected as inconsistent with the scheme and object of the Act. The harmonious construction applied preserved the bar and denied any override by procedural requirements. Case-Laws Indian Laws Tue, 12 May 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40158