TMI Blog1998 (2) TMI 29X X X X Extracts X X X X X X X X Extracts X X X X ..... ounting year relevant to the assessment year 1975-76, the assessee set apart a sum of Rs. 80,000 each for his two minor daughters. The amount set apart, viz., Rs. 1,60,000, as per the entries in the books of account was intended for the education as well as the marriage expenses of his minor daughters. The Gift-tax Officer allowed exemption of Rs. 40,000 for each of the daughters and brought to ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 976] 105 ITR 849. The above order of the Appellate Tribunal is the subject-matter of the reference, on the basis of the direction of this court under section 26(3) of the Gift-tax Act and the following questions of law have been referred for our consideration: "1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal had not erred in law in holding that the provision ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We are of the view, instead of one estimate of Rs. 40,000 each made by the Appellate Assistant Commissioner, the Tribunal arrived at Rs. 80,000 each on the basis of another estimate and, therefore, this court cannot interfere with such an estimate unless it is proved that, the estimate arrived at by the Tribunal was wrong or arbitrary. The Tribunal has taken into account all relevant factors and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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