( 1 ) THE above three reference are made to this court under the E. D. Act, 1953 (34 of 1933) (the Act), relevant to the estate of Pingle Venkatrama Reddy, who died on 3/06/1965. The questions in the reference relate to three life insurance policies obtained by the deceased. Two of the policies relate to a company, by name, Phoenix Assurance Company (Bombay company); the third, relates to the standard Life Insurance Company (the Calcutta company ). The question principally is :whether the proceeds of the policies should be aggregated with the general estate of the deceased, for determination of rate to ascertain the duty payable under the Act.

( 2 ) THE three policies the assured obtained for Rs. 50,000 each. On the Bombay policies, the assured on 13/10/1941, and, for the second time on 15/10/1981, (sic) had taken loans from the Bombay company. From the statement of facts, it is not known what sums were borrowed. On the Calcutta company policy, the assured obtained on 8/06/1933, a sum of Rs. 30,000 and on 17/11/1951, another sum of Rs. 58,000. The undischarged debts on the policies were ascertained to be 71,250. The assured, during his lifetime, on 27/09/1954, assigned