Irrevocable transfer of jewellery for a fixed period is a taxable gift, with value determined under the prescribed valuation rule.

A transfer of jewellery made irrevocable for seventy-four months was treated as a taxable gift because the donor had completely divested ownership during that period and had no right of revocation. A transfer that is not revocable at the donor's mere will, but only after a specified period, falls within the statutory scheme for gifts not revocable for a specified period, even if the Act does not separately define "irrevocable transfer." The value of such a gift had to be computed under the prescribed valuation rule, and any objection based on the absence of income during the relevant period was to be considered by the assessing authority in the first instance.

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Issues: Whether a transfer of jewellery made subject to revocation after a specified period constituted a gift chargeable to gift-tax, and whether its value had to be determined under the statutory valuation provision.

Analysis: The transfer deed showed a complete divestment of the property for seventy-four months, during which the donor had no right to revoke and the donee was entitled to hold and deal with the jewellery as owner. The Court distinguished revocation at the donor's mere will from a transfer that is irrevocable for a specified period, and held that the latter falls within the statutory scheme dealing with gifts not revocable for a specified period. The absence of a separate definition of irrevocable transfer in the Gift-tax Act did not exclude such a transaction from the charging provisions. The Court further held that the value of such a gift had to be computed under the prescribed valuation rule, and that the objection that no income arose during the relevant period was a matter to be considered by the assessing authority in the first instance.

Conclusion: The transfer was liable to be treated as a gift for purposes of gift-tax under the provision dealing with gifts not revocable for a specified period, and the valuation had to be worked out under the prescribed rule.

Ratio Decidendi: A gift that is irrevocable for a specified period, though revocable thereafter, is a taxable gift within the statutory scheme, and its value must be determined according to the prescribed valuation method.

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