Controller Of Estate Duty vs Madhusudan Das Malpani on 30 June, 1993
18. For all the above reasons, we answer the two questions referred to us in the negative, that is, in favour of the Department and against the contentions advanced on behalf of the accountable person. Our answer to question No. 1 is that on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was not justified in holding that there is no finding in the Supreme Court judgment in the case of Madhusudan Das v. Narayani Bai, AIR 1983 SC 114, about the validity or invalidity of the trust known as Seth Mannulal Jagannath Das trust.