Judgment

VENKATACHALIAH, J. :- These appeals, by certificate, under S. 65 of the Estate Duty Act of 1953 (Act for short) - one by the accountable person and the other by the Deputy Controller of the Estate Duty - arise out of and are directed against the judgment dated, 11-10-74 of the High Court of Calcutta, answering, in a reference under S. 64(1) of the Act, the question of law referred for its opinion,

The matter pertained to the determination of the principal value of the estate passing on the death, which occurred on 24-3-1960, of a certain Satya Charan Srimani. Dipti Narayan Srimani, appellant in C.A. 946/1975 is the son of the deceased and is the accountable person.

2. The said Satya Charan Srimani during his lifetime had executed three trust deeds, dated, 8-12-1947, 21-9-1953 and 4-10-1959 respectively. In the proceedings, the nature and effect of the dispositions made under the deeds of the trust, dated 21-9-1953 and 4-10-1959 fell for consideration.

Under the deed, dated 21-9-1953, Satya Charan Srimani as settlor transferred upon trust to himself as trustee 4 items of immovable property, viz., 130 and 133, upper circular Road, and 32/5 and 32/6 Beadon Street, Calcutta. The o