Judgment :- R. JAYASIMHA BABU, J. The question referred to us is with regard to maintainability of the appeal by a donee against whom recovery proceedings were initiated under section 29 of the Gift-tax Act, 1958 (in short "the Act"). The assessment years in question are 1966-67 and 1973-74. The assessment was made by the assessing authority against the legal representatives of the donor from whom the donees have received gifts. Without taking any proceedings against those legal representatives of the donor for the recovery of the amount of tax, recovery proceedings were instituted against the donees under section 29 of the Act. The donees appealed against that order to the Appellate Assistant Commissioner, who allowed the appeal. The Department carried the matter further to the Tribunal contending that the appeals should not have been entertained at the instance of the donees. The Tribunal rejected the points raised by the Revenue and held that the appeal was maintainable and also that the order of the Appellate Assistant Commissioner was right on the merits as well. The Revenue has caused this reference regarding the correctness of the order of the Tribunal on the question of the donees' right to maintain the appeal. Chapter VI of the Gift-tax Act contains provisions which deals with appeals, revisions and references. Section 22 of the Act is the provision which provides for appeals to the Deputy Commissioner of Appeals from the orders of the Assessing Officer. Section 23 of the Act deals with appeals to the Appellate Tribunal. Section 24 deals with the powers of the Commissioner to revise the orders of subordinate authorities. Section 25 provides for an appeal to the Tribunal from the order of the Commissioner made under section 24 or under section 17 or section 17A of the Act. Sections 17 and 17A provide for levy of penalties.Section 22(1) of the Act deals with class of persons who may prefer appeals under that section. Section 22(1) in the opening part gives such right subject to the provisions of sub-section (1A) to "any person". In contrast, the other sections in the Chapter dealing with appeals and revisions confer the right only to "assessees". Section 23(1) enables the assessee to appeal up to the Tribunal. Section 24 enables the assessee to apply to the Commissioner for exercising the revisional powers which power can also be exercised by the Commissioner on his own motion. In contrast, the other sections in the Chapter dealing with appeals and revisions confer the right only to "assessees". Section 23(1) enables the assessee to appeal up to the Tribunal. Section 24 enables the assessee to apply to the Commissioner for exercising the revisional powers which power can also be exercised by the Commissioner on his own motion. Section 25 enables the assessee to appeal to the Appellate Tribunal from the orders of enhancement made by the Chief Commissioner. The marked difference in the expression used in these provisions indicates the legislative intention to confer the right of appeal under section 22 to a larger class than the assessee, while the other provisions earlier referred to limit the right, given under those provisions only to assessees. The term "any person" used in section 22(1) of the Act is, therefore, required to be construed as comprising persons other than the assessees as well, if they object to the orders of the nature referred to in sub-section (1) of section 22 which orders affect them adversely. Section 22(1) , clause (a), enables a person to object to the value of taxable gifts determined under the Act to file an appeal. Clause (b) enables the persons objecting to the amount of gift-tax determined as payable by him under the Act to file an appeal. The other clauses (c) to (g) enable persons objecting to liability to be assessed under the Act; objecting to imposition of penalty by the Assessing Officer under section 17 , objecting to an order made by the Assessing Officer under section 20(2) , objecting to the penalty imposed by the Assessing Officer under section 33 read with section 221(1) of the Income-tax Act; and persons objecting to an order of the Assessing Officer under section 34 , to file appeals. While some of the clauses of section 22(1) come to the rescue only of assessees like section 22(1)(d) , (e) and (g), the other clauses are applicable to non-assessee as well.Section 22(1)(b) of the Act enables a person to object to the amount of gift-tax determined as payable by him to file an appeal. But the determination referred to in this provision, having regard to section 29 of the Act, must be given a liberal construction and is not to be restricted to the determination made in the order of assessment. But the determination referred to in this provision, having regard to section 29 of the Act, must be given a liberal construction and is not to be restricted to the determination made in the order of assessment. This enables the person affected prejudicially by the action taken by the authorities under the Act to have an opportunity of at least one appeal before the appellate forum. There is no other provision under the Act which entitles the donee from whom the tax is sought to be recovered under section 29 of the Act to prefer appeal or revision to any of the authorities. Although, an order under section 29 of the Act is not to be made, unless it is first found that the tax cannot be recovered from the donor, there is no other forum provided under the Act to decide as to whether the power under section 29 of the Act had been properly exercised. Having regard to the scheme of the Act, the language employed in section 22 which is in contrast to the narrower language employed in the other provisions of Chapter VI with regard to persons entitled to file appeals or revisions it must be held that the term "person" in section 22(1) will include the donee against whom the recovery proceedings are taken under section 29 of the Act. The question referred to us is, therefore, answered in favour of the assessees and against the Revenue.