1978 (11) TMI 86

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....wansi in village Adlabad, P.O.Kotana, Tehsil Bagpat. The necessary gift deed was executed on31st March, 1967and duly attested by two witnesses. The deed was registered with the Sub-Registrar on14th April, 1967. The relevant year of account of the assessee commenced on1st April, 1967and ended on31st March, 1968. The GTO valued the agricultural land at Rs. 4,000 per bigha and assessed the value of t....

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.... the gift in question was not at all assessable in the asst. yr. under appeal, 1968-69. 4. After hearing the parties and on a consideration of the facts and circumstances of the case, we are of opinion that the gift in question was not assessable in the year under appeal. The AAC, being a senior officer in the Department, should not have asked for legal opinion of the ITO on the point by settin....

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....tration. There is no dispute that the gift in this case was a completed gift when the gift deed was executed on30th March, 1967. It is true that the deed was registered on14th April, 1967but it operates from the date of execution viz.,30th March, 1967which date falls beyond the accounting year relevant to the asst. yr. 1968-69. In so far as the interpretation of s. 47 is concerned, it is self-evid....