Gift-tax rebate under section 18A applies per instrument of gift, not by aggregating gifts made during the year.

Section 18A of the Gift-tax Act is explained as allowing rebate only when the gift-tax payable in respect of each separate instrument of gift exceeds one thousand rupees. The text distinguishes the computation of total gift-tax under section 3 from the later deduction under section 18A, treating them as operating in different fields. It reads the phrase in section 18A as referring to each instrument individually, with the marginal note supporting that interpretation. Section 13 of the General Clauses Act, 1897 is said to be inapplicable because the statutory context does not require the singular to include the plural.

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Issues: Whether the rebate under section 18A of the Gift-tax Act, 1958 is available only when the gift-tax payable in respect of each instrument of gift exceeds the prescribed threshold, or whether the gifts made during the year can be aggregated for that purpose.

Analysis: Section 18A was read as linking the relief to an individual instrument of gift of property in respect of which the gift-tax payable exceeds one thousand rupees. The total gift-tax payable is ascertained under section 3, while the deduction under section 18A is granted thereafter; the two provisions operate in different fields and do not conflict. The expression in the section was held to refer to each instrument separately, and the marginal note supported that reading. Section 13 of the General Clauses Act, 1897 was held inapplicable because the context did not require the singular to include the plural. The authorities relied upon by the assessee were distinguished as dealing with a different statutory setting.

Conclusion: The rebate under section 18A is allowable only where the gift-tax payable in respect of each instrument of gift exceeds one thousand rupees, and not on aggregation of all gifts made during the year.

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