(1.) THIS is a petition under Section 26(3) of the Gift -tax Act, 1958 (in short 'the Act'). The only question that was considered by the Revenue and the Income -tax Appellate Tribunal, Delhi Bench 'A', New Delhi (in short, 'the Tribunal'), whether there was a gift in terms of Section 4(1)(c) of the Act for the assessment year 1978 -79. According to the Assessing Officer and the Commissioner of Gift -tax (Appeals) (in short, 'the Commissioner'), there was a gift in terms of Section 4(1)(c).of the Act, but the Tribunal held otherwise.
(2.) THE dispute arises in the following background :
(3.) SECTION 4(1)(c) of the Act essentially reads as follows :