Location of gifted property determines gift-tax: receipt abroad avoids tax, direct delivery in India attracts tax. Taxability of gifts in foreign exchange from non-resident donors depends on the location of the property when gifted: receipt by or on behalf of the donee outside India avoids gift-tax; delivery to the donee in India by the donor attracts gift-tax because the delivering agency is the donor's agent; but where the donor sends the instrument at the donee's request the bank/post is treated as agent of the donee and no gift-tax arises.