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TMI Blog1980 (9) TMI 146X X X X Extracts X X X X X X X X Extracts X X X X ..... t for asst. yr. 1971-72 under s. 15(3) of the GT Act. The appeal is delayed by a day. Since it is a postal delay, the delay is condoned and the appeal is admitted. 2. The appellant made three gifts during the year, the particulars of which are as under: S. No. Document No. and Date Value Rs.. Name of the doness 1. 1904/70, dt. 11-5-1970 21,000 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed out to Rs. 1,600. The first appellate authority found that there were three considerations for the gifts, viz., love and affection, education and others. It was on this basis that 1/3rd alone was considered eligible for exemption. He therefore, confirmed the assessment and the appellant is in second appeal. 3. The ld. Representative for the appellant claimed that love and affection was only a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act exempted gifts made "for the education of his children, to the extent to which the gifts are proved to the satisfaction of the GTO as being reasonable having regard to the circumstances of the case". He claimed that it was not solely for education of the children as seen from the wording of the documents and that, at any rate, a reasonable amount has already been allowed by the GTO. 4. We ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... compendious one for "others". Instead of 2/3 and 1/3, it will be reasonable to accept that the ratio should be 50:50. 5. In respect of the daughter, the document reads that the gift is given because of affection, for education and others and for marriage and for facilities thereafter. In this case, education assumes even a minor position than that of the gift to the son. We, therefore, find our ..... X X X X Extracts X X X X X X X X Extracts X X X X
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