Book entries alone cannot establish a valid gift without evidence of acceptance and completed transfer.

Mere credit entries in a firm's books do not by themselves create a valid gift. Book entries may be relevant evidence of a transfer, but a completed gift also requires supporting material showing acceptance and effective completion of the transaction by the donee. On the limited question whether entries alone could establish the alleged gifts, the evidence was insufficient. The claimed gifts were therefore not proved, and the answer was against the assessee.

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Issues: Whether valid gifts to the tune of Rs. 75,000 were made by merely effecting transfer credit entries in the books of the firm.

Analysis: Mere entries in the books of account are relevant evidence of a gift, but they do not by themselves complete or prove a valid and effective transfer in the absence of other supporting evidence showing acceptance and completion of the transaction. The reference was confined to the narrow question whether book entries alone could constitute a valid gift. On that limited question, the evidence was insufficient to sustain the alleged gifts.

Conclusion: No valid gifts were made by mere credit entries in the books of the firm, and the answer was against the assessee.

Ratio Decidendi: A valid gift cannot be established by mere transfer entries in account books; such entries are only evidence and must be supported by other material showing a completed gift and acceptance by the donee.

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