RAMANUJAM J.

The assessee is a prominent and eminent surgeon running a nursing home at Madras. One G. R. Kanagasabai Pillai of Kariamangalam in Tanjore District underwent treatment in the nursing home of the assessee during the period from November, 1957, to December, 1958, for a chronic ailment. The said Kanagasabai Pillai got completely cured and he had paid to the assessee a sum of Rs. 4, 082 as fees for the professional services rendered by him Kanagasabai Pillai owned about 300 acres of lands, both wet and dry. He had no issues. By a deed dated March 9, 1960, he gifted to the assessee 31.56 acres of manja lands and 1.82 acres of punja lands situate in Kariamangalam village specifically mentioning in the gift deed that the assessee had shown him kindness, infused in him self-confidence and gave him sense of protection which he could never forget, that the assessee's kindness and protection had created a feeling of gratitude in his mind and to translate it into concrete shape, he was making the gift of the lands to the assessee. The gift deed specifically provided that the assessee should not sell the lands gifted to him without obtaining the permission of the donor.

C