Govinda Bhat, J.—This is a reference under section 64(2) of the Estate Duty Act, 1953, as it is stood before amendment. The question of law referred for our opinion is :

"Whether, in the circumstances of the case, the sum of Rs. 33,000 is liable to be charged in respect of the alleged jewellery owned by the deceased ?"

2. One Sri Murigappa Chigateri died on January 12, 1957, and his son is the accountable person under the Estate Duty Act, and therefore, he filed a statement of account declaring the principal value of the estate of the deceased at Rs. 2,65,904. The Assistant Controller of Estate Duty, Bangalore, determined the net principal value of the estate at Rs. 5,64,304. In arriving at the said value, the Assistant Controller included, inter alia, a sum of Rs. 33,000 alleged to be the value of the jewellery in the possession of the deceased at the time of his death. In the estate duty return the accountable person had shown the value of the jewellery in the possession of deceased at Rs. 2,300 only. The Assistant Controller relied on the fact that the deceased had estimated the jewellery at Rs. 50,000 in the wealth statement furnished by him in connection with his asses