Context-specific statutory definitions cannot enlarge tax exemptions by borrowing from a welfare statute.

A statutory definition is context-specific and cannot be imported into the Income-tax Act to enlarge a gift-tax exemption where the taxing statute uses a narrower scheme and expressly limits exemptions. The Delhi High Court noted that the Maintenance and Welfare of Parents and Senior Citizens Act serves a welfare purpose distinct from the fiscal object of the Income-tax Act, so the term "relative" in the former could not be transplanted into the latter. The Court also stated that writ relief was not available to cancel or nullify the gift deed merely to avoid tax liability, and declined the alternative prayer in writ jurisdiction.

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Issues: (i) Whether the definition of "relative" in the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 could be imported into the Income-tax Act, 1961 so as to extend gift-tax exemption to a donee falling within that definition; (ii) Whether the writ court could grant cancellation of the gift deed or treat it as void ab initio on the footing that the transfer should not attract tax.

Issue (i): Whether the definition of "relative" in the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 could be imported into the Income-tax Act, 1961 so as to extend gift-tax exemption to a donee falling within that definition.

Analysis: The two enactments serve different objects. The senior citizens legislation is a welfare statute directed to maintenance and protection of senior citizens, while the income-tax law is a fiscal enactment intended to tax gifts except where the legislature has specifically carved out exemptions. The definition of "relative" in the senior citizens statute is expressly contextual and cannot be transplanted into the tax statute, particularly when the Income-tax Act uses a narrower definition and deliberately limits the exemption scheme. The Court also declined to supply any supposed omission or to rewrite the statutory scheme.

Conclusion: The definition of "relative" in the Senior Citizens Act cannot be imported into the Income-tax Act, and the claimed exemption is not available.

Issue (ii): Whether the writ court could grant cancellation of the gift deed or treat it as void ab initio on the footing that the transfer should not attract tax.

Analysis: The relief sought was found to be aimed at avoiding tax liability rather than advancing the welfare purpose of the senior citizens legislation. Section 23 of the senior citizens statute was held to provide an additional remedy in specified circumstances, but not to bar the donee from challenging the transfer in accordance with law. The Court therefore found no basis to grant the alternative relief in the writ proceedings.

Conclusion: The alternative prayer for cancellation or nullification of the gift deed was declined.

Final Conclusion: The writ petition failed in its challenge to extend the tax exemption by borrowing a definition from another welfare statute, and no ancillary relief was granted in the writ jurisdiction.

Ratio Decidendi: A statutory definition is context-specific and cannot be imported into a different enactment with a distinct object and scheme; courts cannot enlarge or rewrite a clear taxing provision by supplying omissions or extending exemptions beyond the legislature's express language.

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