Marriage-linked gift-tax exemption extends broadly to dependent family members, including daughters-in-law, under the Gift-tax Act.

Gifts of gold ornaments and silver articles by a Hindu undivided family to daughters-in-law on marriage were treated as exempt under section 5(1)(vii) of the Gift-tax Act, 1957, because the phrase "on the occasion of marriage" was interpreted broadly and was not limited to the exact wedding date. The Tribunal also treated dependent female family members as eligible donees, holding that "dependent" does not require proof of being wholly and mainly dependent on the donor and may cover relatives supported by the family for maintenance. The CBDT circular supported this construction, and exemption was sustained to the extent allowed.

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Issues: Whether gifts of gold ornaments and silver articles made by a Hindu undivided family to daughters-in-law on the occasion of marriage qualified for exemption under section 5(1)(vii) of the Gift-tax Act, 1957, and whether such donees could be treated as dependent relatives for that purpose.

Analysis: The expression "on the occasion of marriage" was construed broadly and was not confined to the exact date of marriage. For determining the meaning of "dependent" under the Gift-tax Act, the Tribunal drew support from the definition and interpretation of the term in the Expenditure Tax Act, 1957 and the Supreme Court's view that dependence in family settings may extend to wives and unmarried daughters of coparceners and widows. The provision in section 5(1)(vii) did not require the donee to be wholly and mainly dependent on the donor. The CBDT circular specifically stated that exemption would be available where a Hindu undivided family made gifts to members of the family dependent upon it for support and maintenance, which supported inclusion of dependent female relatives.

Conclusion: The gifts to the extent of Rs. 10,000 were eligible for deduction under section 5(1)(vii) of the Gift-tax Act, 1957.

Final Conclusion: The departmental appeals failed and the assessee's claim for exemption was sustained, with the cross objections having no surviving controversy.

Ratio Decidendi: For exemption under section 5(1)(vii) of the Gift-tax Act, 1957, the phrase "on the occasion of marriage" is not confined to the exact date of marriage, and a dependent relative of a Hindu undivided family may include female family members dependent on the family for support and maintenance without proof of wholly and mainly dependent status.

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