N.K.AGRAWAL, J.

1. The following question of law has been referred at the instance of the accountable person under s. 64(1) of the ED Act, 1953 (for short, "the Act") :

"Whether, on the facts and in the circumstances of the case, the Tribunal was correct in rejecting the accountable persons contention that the reopening of the assessment proceedings was bad in law ?"

2. Joginder Singh died on 3rd November, 1981. His widow, Smt. Dhan Kaur, filed return under the Act, furnishing the account of the estate left by her late husband and showing the principal value of half property as assessable under the Act. Assessment of estate duty was made by the Asstt. CED on 19th February, 1983 on one half of the net estate of the deceased, valued at Rs. 2,54,483. Thus, as intended by the accountable person, assessment was made on only half of the estate of the deceased. The late Joginder Singh was the Karta and sole surviving male coparcener of his Hindu undivided family (HUF). He was survived by his widow and a married daughter. He had left behind 19 acres of agricultural land valued at Rs. 3,12,645 and foodgrains, milch cattle, agricultural implements etc., valued at Rs. 10,000. Value of