JUDGMENT

S.B. Majmudar, J.-This appeal by certificate of fitness to appeal granted by the High Court of Judicature, Andhra Pradesh under Section 65 of the Estate Duty Act, 1953 (hereinafter referred to as the Act ) is moved by the appellant accountable person who has felt aggrieved by the answers given by the High Court against him on five out of six questions referred by the Income-Tax Appellate Tribunal, Hyderabad for opinion of the High Court under Section 64(1) of the Act. The following six questions were so referred :

"1. Whether on the facts and in the circumstances of the case, the sum of Rs. 1,56,971 relating to the Estate of late Mazharunnisa Begum is includible in the estate of the deceased as passing under Section 5 of the Estate Duty Act.

2. Whether on the facts and in the circumstances of the case, the sum of Rs. 8,23,697, representing the amount spent on the construction of quarters of dependents and the Khanazadas, is includible in the estate of the deceased under Section 9 of the Estate Duty Act.

3. Whether on the facts and in the circumstances of the case the sums of Rs. 12,61,649 and Rs. 8,85,850 representing respectively sale proceeds of the property known as persi