1984 (1) TMI 43

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.... a notice of reopening of assessment issued under s. 59 of the E.D. Act, 1953. One, Kasturbai Chandrasen Ashar, died on October 11, 1975. Her husband as the accountable person submitted an account for the purposes of estate duty to the Department. The estate included 81 shares of the International Cotton Corporation (P) Ltd., a private limited company. Based upon a valuation report, the value o....

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.... should be submitted within 30 days. On May 11, 1980, the chartered accountants of the petitioners asked the Asst. Controller for particulars as to why the notice had been issued. There was no response. On August 14, 1980, this petition was filed by the sons of Kasturbai and her late husband impugning the notice. There is no affidavit in reply, but a copy of the reasons recorded by the Asst. Co....