C.S.P. Singh, J.

1. THE Income-tax Appellate Tribunal, Allahabad Bench, Allahabad, has referred the following questions for the opinion of this court:

"(1) Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the estate duty proceedings had not become time-barred in this case in terms of the provisions contained in Section 13A(a) of the Estate Duty Act ?

(2) Whether, on the facts and in the circumstances of the case, the Tribunal was correct in confirming the order of the Appellate Controller directing the Assistant Controller to re-do the assessment after providing full opportunity of hearing to the karta of the HUF also ?"

2. THE dispute relates to the estate of the deceased, Shyam Hari Singhania, who died on the 3rd December, 1960. At the time of his death he owned separate and self-acquired property, and was also a member of a HUF of which Sir Padampat Singhania, his father, was the karta. Shyam Hari Singhania had no issue, and left behind him a widow, Smt. Usha Devi, and his mother, Lady Ansuiya Devi (class I heirs under the Hindu Succession Act). On the 1st August, 1961, Lady Ansuiya Devi filed a return showing the net valu