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TMI Blog1978 (11) TMI 86X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 the gift at Rs. 1,24, 400. The taxable gift was worked out at Rs. 1,14,400 after a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -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 setting aside the assessment and directing him to consider if the gift in question is asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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-evident but it is also concluded by a decision of the Supreme Court in K.J. Nathan vs. Mar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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