Since the leased premises that is how we propose to describe the building leased to the appellant by the les sors admittedly belonged to the estate of the deceased, the rent payable by the appellant was a fortjori an amount which in law belonged to the estate and hence the Assistant Con troller issued a notice dated 9th January, 1962 to the appellant under section 73, sub section (5) of the read with section 46, sub section (5A) of the Indian Income Tax Act, 1922 (hereinafter referred to as the Act of 1922) pointing out that "a sum of Rs. 1,40,090.20 is due from Shri Tulsi Charan Deb and others on account of estate duty as accountable persons to the estate of late Rai Bhupati Nath Deb" and requiring him to pay forth with "any amount due from you to or, held by you, for, or on account of the said estate of Bhupati Nath Deb Bahadur" upto the amount of Rs. 1,40,090.20 as also "to pay money which may subsequently become due from you to them or which you may subsequently hold for or on account of them upto the amount of arrears still remaining unpaid, forthwith on the money becoming due or being held by you as aforesaid, as such payment is required to meet the amount duo by the accountable person in respect of arrears of estate duty".