Judgment : JANARTHANAM, J. The assessment relatable to gift-tax is for the assessment year 1971-72. The assessee, Sri G. V. Kasturiswamy Naidu, Coimbatore, gifted 10.06 acres of agricultural land to his minor daughter, Sunitha, aged five then. He in respect of the land so gifted, claimed exemption on two grounds. Firstly, the gift was intended to provide for her marriage. Secondly, it was for the purpose of meeting the educational expenses. He valued the lands so gifted at Rs. 50, 000. The Gift-tax Officer, in turn, valued the lands so gifted at Rs. 1, 10, 600 The assessee also made certain other gifts. The Gift-tax Officer ultimately determined the taxable gift at Rs. 4, 35, 260. While arriving at the quantum of taxable gift as stated above, the Gift-tax Officer granted statutory exemption of Rs. 5, 000 under sub-section (2) of section 5, under section 5(1)(xii) of the Gift-tax Act, 1958 (for short "the Act"), relating to educational expenses. He did not, however, grant any exemption to provide for the marriage expenses of the minor daughter, inasmuch as the marriage of such minor daughter could not have been in contemplation at that point of time. The aggrieved assessee filed an appeal before the Commissioner of Income-tax (Appeals). In the appeal so filed, the assessee did not at all challenge the valuation adopted by the Gift-tax Officer in respect of agricultural lands and what was challenged was the exemption granted under section 5(1)(xii) of the Act. The Commissioner of Income-tax (Appeals), Coimbatore, enhanced the exemption limit under section 5(1)(xii) from Rs. 5, 000 to Rs. 25, 000. He provided the basis for such an enhancement thus. He fixed a reasonable sum of Rs. 2, 000 per year to meet the educational needs of the minor daughter. Since she was aged five then, he estimated the educational expenses for a period of 20 years and, therefore, he calculated the total expenses to meet the educational needs of the minor daughter at Rs. 40, 000. He also was of opinion that the portion of the land, which would provide over a period of 20 years a sum of Rs. 40, 000 can be fixed in value at Rs. 25, 000. Since the Gift-tax Officer has also provided exemption of Rs. 5, 000 under section 5(1)(xii), he enhanced the same by a further sum of Rs. 20, 000. 40, 000 can be fixed in value at Rs. 25, 000. Since the Gift-tax Officer has also provided exemption of Rs. 5, 000 under section 5(1)(xii), he enhanced the same by a further sum of Rs. 20, 000. Ultimately, he ordered the sum of Rs. 20, 000 to be deducted from the total taxable gift of Rs. 4, 35, 260The aggrieved assessee filed an appeal before the Income-tax Appellate Tribunal, Madras. The Tribunal, in turn concurred with the views of the Commissioner of Income-tax (Appeals) as relatable to the grant of exemption under section 5(1)(xii) of the Act. It is on these facts, the Tribunal at the instance of the assessee referred the questions of law as below for the opinion of this court, "1. Whether, the Tribunal is justified in holding that the amount of Rs. 2, 000 per annum would be sufficient for the cost of education of the assessees minor child having regard to the facts and circumstances of the case ? 2. Whether the Tribunal was justified in restricting the amount of gift exempted under section 5(1)(xii) at Rs. 25, 000 having accepted the total amount of expenditure for education of the assessees minor child amounting to Rs. 40, 000 over a period of twenty years at Rs. 2, 000 per year ?" Arguments of Mrs. Aparna Nandakumar, learned counsel, representing Mr. R. Venkataraman, learned counsel appearing for the applicant, and of Mr. R. Sivaraman, learned counsel, representing Mr. C. V. Rajan, learned junior standing counsel, representing the Revenue, were heard. The answers to questions Nos. 1 and 2, we rather feel, are interconnected in such a way as is not possible to separate one question from the other and, therefore, it is, we proceed to enter into the arena of discussion in finding out the answers for both the questions in a compendious fashion. The exemption granted in respect of agricultural lands under section 5(1)(xii) of the Act quantified in a sum of Rs. 5, 000 by the Gift-tax Officer is rather incredibly low, on the facts and in the circumstances of the case. The Commissioner of Income-tax (Appeals) raised the exemption limit in a further sum of Rs. 20, 000 making it a total of Rs. 25, 000. The Tribunal also concurred with the view of the Commissioner of Income-tax (Appeals). 5, 000 by the Gift-tax Officer is rather incredibly low, on the facts and in the circumstances of the case. The Commissioner of Income-tax (Appeals) raised the exemption limit in a further sum of Rs. 20, 000 making it a total of Rs. 25, 000. The Tribunal also concurred with the view of the Commissioner of Income-tax (Appeals). We have already stated in the summation of the case as to how the Commissioner of Income-tax (Appeals) enhanced the exemption limits under section 5 (1)(xii) to a further sum of Rs. 20, 000. The basis provided for such enhancement by the Commissioner of Income-tax (Appeals), as laterly approved by the Tribunal, on the facts and in the circumstances of the case, cannot at all be stated to be suffering from any infirmity of appreciation of the factual matrix of the case, warranting any interference. Therefore, we are of the view, that the order of the Tribunal determining the quantum of exemption under section 5(1)(xii) of the Act cannot at all be stated to be not sustainable in law, inasmuch as the relevant factual matrix had been properly appreciated in arriving at the figure of exemptionFor the reasons as above, we answer both the questions as below. The Tribunal is justified in holding that the amount of Rs. 2, 000 per annum would be sufficient for the cost, of education of the assessees minor child, having regard to the facts and circumstances of the case. The Tribunal was further justified in restricting the amount of gift exempted under section 5(1)(xii) of the Act at Rs. 25, 000. The tax case is thus disposed of. There shall, however, be no order as to costs, on the facts and in the circumstances of the case.