GOPAL RAO EKBOTE, J.

( 1 ) THIS is an application under Article 226 of the Writ off prohibition restraining the respondents from proceeding with the enquiry in pursuance of a notice dated 31-1-1967.

( 2 ) THE relevant facts are that the petitioners are real brothers. Their father Sri Venuir Satyanarayana Rao died on 2-12-1957 leaving an estate liable to estate duty under the Estate Duty Act (XXXIV of 1953), hereinafter the return, According to the petitioner all the relevant facts were disclosed and brought to the notice of the Assistant Controller of Estate Duty.

( 3 ) THE assessing authority, by its order dated 27-6-1964, assessed the estate of the deceased at Rs. 2, 99, 765 and imposed a duty of Rs. 20, 546. 16 P. Since the petitioners had paid Rs. 1,491. 83 P. by way of advance, the balance was paid by them on 13-8-64.

( 4 ) THEY wee however, not satisfied with the order of the assessing authority. Therefore, they preferred an appeal to the Appellate Assistant Commissioner of Estate Duty. The appellate authority, by its order dated 19-9-1965, gave some reliefs, the chief among which was a relief to the extent of Rs. 21, 312. 00 from the principal value of the estate towards mai

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