62. Appeal against orders of Controller.
(1) Any person--
(a) objecting--
(i) to any valuation made by the Controller, or
(ii) to any order made by the Controller determining the estate duty payable under section 58 or section 59, or
(iii) to any penalty levied by the Controller under section 60, section 72 or section 84, or
(iv) to any penalty imposed by the Controller under sub- section (1) of section 46 of the Indian Income- tax Act, 1922 , (11 of 1922 ) as applied under sub- section (5) of section 73 for the purposes of estate duty, or
(b) denying his liability to the amount of estate duty payable in respect of any property, may, within thirty days of the date of the receipt of the notice of demand under section 73, appeal to the Appellate Controller in the prescribed form which shall be verified in the prescribed manner: Provided that no appeal shall lie under sub- clause (iv) of clause (a) unless the duty has been paid before the appeal is filed.
(2) The Appellate Controller may admit an appeal after the expiry of the thirty days referred to in sub- section (1) if he is satisfied that there was sufficient cause for not presenting it within that period.
(3) The Appellate Controller shall fix a day and place for the hearing of the appeal and may from time to time adjourn the hearing.
(4) The Appellate Controller may--
(a) at the hearing of an appeal, allow an appellant to go into any ground of appeal not specified in the grounds of appeal;
(b) before disposing of an appeal, make such further inquiry as he thinks fit or cause further inquiry to be made by the Controller.
(5) In disposing of an appeal, the Appellate Controller may pass such order as he thinks fit which may include an order enhancing the estate duty or penalty: Provided that no order enhancing the estate duty payable or penalty shall be made unless the person affected thereby has been given a reasonable opportunity of showing cause against such enhancement.
(6) The Appellate Controller shall, on the conclusion of the appeal, communicate the order passed by him to the appellant and to the Controller.