JUDGMENT

PATHAK J. - The Income Tax Appellate Tribunal has referred the following questions u/s 66(1), Income Tax Act, 1922 :

"1. Whether, on the facts and circumstances of the case, the gifts of Rs. 10,000 made by Ganpati Devi to Sita Devi on May 12, 1960, of Rs. 10,000 made by Murari Lal to Saroj Kumari on March 23, 1960, and Rs. 10,000 made by Brijmohan to Smt. Pushpa Devi on September 21, 1960, were valid in law ?

2. If the answer to the aforesaid question is in the affirmative, whether the Tribunal was legally right in confirming the disallowance of interest on the same ?"

For the purposes of appreciating the facts in this case, it appears convenient to set out the following family tree :

Brijmohan and his sons, Murari Lal and Prabhat Kumar, constitute a partnership firm, Messrs. Bhau Ram Jawahar Mal, the assessee before us, On March 23, 1960, Murari Lal purported to make a gift of Rs. 10,000 to his sister, Saroj Kumari. On May 12, 1960, Ganpati Devi purported to make a gift of Rs. 10,000 to her daughter-in-law, Sita Devi. On September 21, 1960, Brijmohan pur