RAJIVE BHALLA
COMMISSIONER OF INCOME TAX – Appellant
Versus
JAWAHAR LAL OSWAL – Respondent
Rajive Bhalla, J.
1. The Revenue has filed IT Appeal Nos. 48, 49, 169 of 1999 and GT Appeal No. 10 of 2004 challenging orders passed by the Income-tax Appellate Tribunal, Chandigarh (for short "the Tribunal"). As the controversy and the substantial questions of law are common to all appeals, facts are being taken from IT Appeal No. 49 of 1999. The dispute in hand, briefly put, relates to the genuineness of two monetary gifts received by the assessee for and on behalf of his daughters on the occasion of their marriage. The gifts, as admitted, were received from Dr. O.S. Gill and Shri B.P. Bhardwaj, by demand drafts, while the assessee was in London. The AO, served a notice under s. 143 of the IT Act, 1961 (hereinafter referred to as "the Act"), addressed queries to the assessee, obtained information through the CBDT, from the Inland Revenue, Great Britain, examined Dr. O.S. Gill but as he was not satisfied with the explanation proffered by the assessee, on the basis of material on record, held that the assessee has not been able to prove the genuineness of the gifts. The AO, therefore, raised an inference, under s. 69A of the Act and held that the gifts represent the income
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