CONTROLLER OF ESTATE DUTY, GUJARAT vs KANTILAL TRIKAMLAL

The Supreme Court interpreted the Estate Duty Act, 1953, specifically Sections 2(15), 5, 9, and 27, clarifying that estate duty applies to property passing on death, including dispositions made within two years prior to death. The Court held that a relative, as the accountable person, is liable for estate duty on the difference between the deceased's legal entitlement and the actual share received, emphasizing that the Act's provisions must be strictly interpreted without room for equity. The judgment reinforces the principle that tax statutes require clear language and do not allow for judicial supplementation of legislative intent.