Gift-tax exemption for dependent relatives requires marriage occasion too; punctuation cannot override clear statutory wording.

The Andhra Pradesh HC held that exemption under section 5(1)(vii) of the Gift-tax Act, 1958 required more than proof that the donee was a dependent relative. The clause was construed as an integrated provision, so a gift was exempt only when made on the occasion of the relative's marriage and within the prescribed monetary limit. The Court rejected reliance on punctuation to separate the dependency wording from the marriage requirement, holding that clear statutory language must be given its ordinary meaning. On that interpretation, the gift to the assessee's mother did not qualify for exemption and the reference was answered against the assessee.

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Issues: Whether a gift made to the assessee's mother was exempt under section 5(1)(vii) of the Gift-tax Act, 1958, as a gift to a relative dependent upon him for support and maintenance.

Analysis: The exemption clause was held to require more than dependency alone. The words relating to dependency and the words relating to the occasion of marriage were read together as part of one integrated provision. The Court held that punctuation, including the comma relied on by the Tribunal, could not override the plain language of the clause. Since the provision was clear and unambiguous, it had to be construed according to its ordinary and natural meaning, and a gift to a dependent relative was exempt only when made on the occasion of the relative's marriage, subject to the monetary limit prescribed.

Conclusion: The gift to the assessee's mother was not exempt under section 5(1)(vii); the reference was answered in the negative and against the assessee.

Ratio Decidendi: Where the language of an exemption provision is clear, punctuation cannot be used to sever its parts or alter its meaning, and dependency alone does not satisfy a clause that also requires the gift to be made on the occasion of the relative's marriage.

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