- (1.) The Income-tax Appellate Tribunal, Allahabad, has referred the following questions of law under Section 26(1) of the Gift-tax Act, 1958, hereinafter referred to as "the Act", for the opinion of this Court. "1. Whether, on the facts and in the circumstances of the case the Tribunal was legally correct in holding that the rules framed under the Stamp Act are not conclusive of determination of market value of properties ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was legally correct in holding that there was no deemed gift in the case ?"
(2.) The present reference relates to the assessment year 1981-82.
(3.) Briefly stated the facts giving rise to the present reference are as follows :;