(1.) IN this reference under Section 26(1) of the Gift-tax Act, 1958, the question referred by the INcome-tax Appellate Tribunal, Cochin Bench, at the instance of the Commissioner of Gift-tax. Kerala, is the following:
(2.) THE reference relates to the assessment year 1961-62, the relevant account year being the financial year ending on March 31, 1961.
(3.) THEIR Lordships explained the meaning of the word "purpose" in the second limb of the provision by observing that: