https://www.taxtmi.com/caselaws?id=60805 The deceased partner's share in a partnership firm's investment allowance reserve was treated as property passing on death for estate duty purposes, because sections 5 and 6 of the Estate Duty Act bring within charge property passing on death or within the deceased's disposing capacity. However, the reserve was subject to the statutory limitations in section 32A(5) of the Income-tax Act and the related consequences under section 155(4A), so the interest could not be valued as an unrestricted asset. The deceased had a real but circumscribed right in the reserve, and valuation had to reflect the remaining utilisation period and surrounding facts, resulting in inclusion at a discounted amount rather than full face value. en-us Thu, 03 Feb 1983 00:00:00 +0530 Sat, 08 Jan 2011 11:33:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60805 The deceased partner's share in a partnership firm's investment allowance reserve was treated as property passing on death for estate duty purposes, because sections 5 and 6 of the Estate Duty Act bring within charge property passing on death or within the deceased's disposing capacity. However, the reserve was subject to the statutory limitations in section 32A(5) of the Income-tax Act and the related consequences under section 155(4A), so the interest could not be valued as an unrestricted asset. The deceased had a real but circumscribed right in the reserve, and valuation had to reflect the remaining utilisation period and surrounding facts, resulting in inclusion at a discounted amount rather than full face value. Case-Laws Income Tax Thu, 03 Feb 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60805