Fakkir Mohammed, J.

1. The reference has been made by the Income-tax Tribunal, Madras, at the instance of the assessee under s. 26 of the G.T.Act, 1958. The question that is referred is as follows :

"Whether the assessee had made a gift of the properties in favour of his daughter and grandchildren under the deed February 11, 1969 ?"

2. The assessee executed a registered document on February 11, 1969, in favour of his wife, styling it as a settlement deed in respect of 18 items of properties, which belonged to him. In the said document, he has granted a life estate without any power of alienation in favour of his wife jointly with himself, and the latter shall enjoy the properties described therein, in the event of he pre-deceasing his wife. He has further provided in the document that his grand-daughter, Priavathi, grandson, Jayaprakasan, and his daughter, Seethalakshmi Ammal, should take their respective items of properties marked for them as their absolute properties after the lifetime of himself and his wife. Earlier to that, he had executed two gift deeds on January 29, 1969 four gift deeds on January 30, 1969, two gift deeds on February 1, 1969, and two gift deeds on Febr