Recovery of unpaid estate duty on gifted property out of sum received on its transfer won't attract

IT: Where settler of assessee-trust gave a property to trust which was subject to first charge under Estate Duty Act, in view of fact that on acquisition of said property entire compensation amount was appropriated for payment of estate duty arrears, and nothing remained there for utilisation of trust, there was no violation of provisions of section 13(1)(c) and 13(3) and, therefore, assessee's claim for exemption under section 11 was to be allowed