Per Shri U.T. Shah, Judicial Member. - In this appeal, the assessee is contesting the gift-tax levied by the G.T. authorities on the value of certain shares transferred by her to the trust viz. Bhavana Nalnikant Trust. The assessee is an individual. The assessment year is 1980-81 and the relevant previous year ended on 31-3-1980.

2. By a deed of trust dated 19-2-1979, the assessee had created an irrevocable trust with initial sum of Rs. 1,000. Under the said trust the trustees were required to give the entire income of the trust (after meeting incidental expenses), to the assessee for a period of 30 years from the date of execution of the deed or till the death of the assessee whichever period expired earlier. It was also provided in the said deed as to who shall be the beneficiaries in the event of the death of the assessee. By her letter dated 22-2-1979 addressed to the trustees of the said trust, the assessee informed the trustees that she was making gift of certain shares which were of her individual ownership to the said trust with a request to accept the same. Along with the said letter, the assessee had also sent transfer forms duly completed by her in respect of the sai