Veeraswami, J.- The following questions have been referred to us under section 66 (1) of the Indian Income-tax Act: “(1) Whether the provisions of section 16(3)(a)(iii) apply to the facts of this case? (2) Consequently whether the income of Rs. 2,044 from the house property in Bunder Street, Madras, is taxable in the assessee’s hands?” The Tribunal found that the transfer of the sum of Rs. 45,000 was by way of gift to the wife and that the statement made to the Town Kazi could not be accepted because he did not speak to facts from his personal knowledge. Once the statement of the Town Kazi is not accepted, the only other material was the statement by the assessee himself that he had made a gift of the sum of Rs. 45,000 to his wife. This is purely a question of fact and the Tribunal was right in its view that the transfer was not shown to be for adequate consideration. The sum paid by the assessee to his wife formed the major part of the consideration for purchase of the house by the wife. The contention for the assessee is that the income from the house property cannot be referred to the sum of Rs. 45,000 made as a gift to the wife. We are of view that this contention cannot be accepted. It makes no difference when what is transferred to the wife is converted into another form of asset for purposes of section 16 (3). J.B. Greaves v. Commissioner of Income-tax1. The questions referred to us are answered against the assessee with costs. Counsel’s fee Rs. 250. V.S. ----- Answered accordingly.