1997 (3) TMI 49

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....NGH J.---The Revenue filed an application (R. A. No. 225 ASR of 1979), before the Income-tax Appellate Tribunal, Amritsar (hereinafter referred to as "the Tribunal"), requiring the Tribunal to draw up a statement of the case and refer the following two questions of law arising from the Tribunal's order dated August 29, 1979, in E. D. A. Nos. 8 and 11(ASR) of 1978-79, to this court for its opinion ....

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....r Singh for a sum of Rs. 40,000. The Assistant Controller of Estate Duty estimated the value of the subject-matter of the sale at the rate of Rs. 13,250 per acre. Thus, according to the Assistant Controller of Estate Duty, the total value of the subject-matter of sale was Rs. 2,18,997 as against the sale consideration of Rs. 40,000. The value of the land being much more, the Assistant Controller o....

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....15) of section 2 of the Estate Duty Act, 1953, were not attracted to the case of the deceased ?" We have heard learned counsel for the Revenue, Mr. R. P. Sawhney, senior advocate. The contention of learned counsel for the Revenue is that the present case is a case of deemed gift to the tune of Rs. 1,78,997 in view of the provisions of section 9 read with Explanation 2 to section 2(15) of the....