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Estate Duty - Interpretation of Sec.73A - Applicability of penalty.

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....that section 73A of the Estate Duty Act bars the commencement of Estate Duty proceedings by revenue authorities beyond the statutory period of 5 years but if the proceedings have commenced otherwise, it does not operate as a bar to their completion. In other words there is no bar to the completion of assessment on the basis of a voluntary return filed beyond the statutory period of 5 years. It was....

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....he period, specified in section 73A, penalty proceedings for late filing of the return can be initiated and the penalty levied in pursuance of the same. This is so because:- (i) Section 73A only bars the commencement of the proceedings by the revenue authorities. (ii) The provisions for filing a return are contained in section 53 and section 56 of the ED Act. Thus the return filed voluntaril....