Gift-tax applies only on completed transfer, so a deed registered after year-end was not taxable in that assessment year.

Gift-tax is chargeable only when the transfer constituting the gift is completed in the relevant previous year. Where an exchange transaction was treated as a deemed gift, the decisive event was registration of the deed, not its earlier execution. Because registration was completed after the close of the previous year ending 31 March 1982, the transfer did not become taxable in assessment year 1982-83. The argument that execution date or relation-back principles should fix taxability was rejected for gift-tax purposes, since the taxable event arose only on completion of the transfer.

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Issues: Whether the exchange transaction amounted to a taxable gift in the assessment year 1982-83, having regard to the date on which the deed was registered and the close of the relevant previous year.

Analysis: Gift-tax is attracted under the Gift-tax Act only when a gift is made in the relevant previous year. A gift, including a deemed gift, becomes chargeable only when the transfer is complete. The question therefore turned on the date of completion of the transfer. The reliance placed on the execution date was rejected because registration was completed only on 21 April 1982, after 31 March 1982, which was the end of the previous year relevant to the assessment year in question. The principle that registration may relate back for limited purposes did not alter the fact that the taxable event occurred only upon registration after the close of the previous year.

Conclusion: No gift-tax liability arose in assessment year 1982-83, and the deemed gift could not be brought to tax in that year.

Ratio Decidendi: For gift-tax purposes, the transfer is chargeable only when the taxable event is completed in the relevant previous year, and a deed registered after the close of that year cannot be taxed in that assessment year merely because it was earlier executed.

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