ASHOK SINGH vs ASSISTANT CONTROLLER OF ESTATE DUTY.CALCUTTA AND OTHERS.

The Supreme Court ruled that under Section 73A of the Estate Duty Act, 1953, the time limit for initiating proceedings for the levy of estate duty is five years from the date of death, and if this period has expired, the requirement for a certificate under Section 56(2) does not arise. The Court held that while the liability for payment of duty remains, the initiation of proceedings is barred after five years, thus affirming the High Court's decision to cancel the notice issued under Section 58(2). The Court emphasized that the plain meaning of the statute must be adhered to in interpretation.