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c. That conditional/revocable gift being outside the preview of a valid gift does not constitute a gift received by any person to be subjected to tax under provisions of Section 56(2)(v) of the Act and therefore can not be subjected to tax as any sum of money received without consideration under any provisions of the Act.

d. That the appellant being a senior citizen having attained more than 75 years of age who is not carrying on any kind of profession or occupation and merely had his sustenance on pension income from government service wherein he has retired more than 15 years before can not be deemed to be in receipt of any income directly or indirectly by way of such gifts received which can be subjected to tax.