Estate duty exemption for gifts to sons left no referable question of law under the statutory framework.

Gifts made by the deceased to his sons were treated as falling within the statutory exemption under section 33(1)(o) of the Estate Duty Act, 1953, because the Tribunal found the exemption conditions satisfied on the facts. On that basis, no referable question of law arose from the inclusion of those gifts in the principal value of the estate, since the provision itself covered property passing under a gift to the specified relatives within the statutory framework. The alternative contention was not treated as determinative. The application for reference was rejected.

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Issues: Whether any referable question of law arose from the Tribunal's order concerning inclusion of gifts made to the deceased's sons in the principal value of the estate, and whether the exemption under section 33(1)(o) of the Estate Duty Act, 1953, applied.

Analysis: The gifts were made to the deceased's sons, and the Tribunal had held that the statutory conditions for the exemption were satisfied. On that footing, the matter involved no question requiring reference, because the provision itself covered property taken under a gift to the specified relatives within the statutory framework. The alternative contention was not the basis of the decision.

Conclusion: No referable question of law arose, and the application for reference was rejected.

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