(1.) THIS is a reference under Section 64(1) of the Estate Duty Act 1953, made by the Income-tax Appellate Tribunal.
(2.) THE Income-tax Appellate Tribunal has submitted the statement of case seeking the opinion of this court on the question of law as stated in the statement of case which is as under ;
(3.) IT is alleged that on varions dates in the calendar year 1958, the deceased, G.D. Anklesaria, withdrew sums of cash from the said firm and made gifts of the same to his wife, Smt. Frenibai, from time to time during the calendar year 1958. These amounts totalled up to Rs. 1,00,000. Smt. Frenibai, in turn, kept this money with her for some time and later on invested the same in the said firm on the dates mentioned below : <FRM>JUDGEMENT_878_ITR122_1980Html2.htm</FRM>