Bhavnesh Saini, J.M. - This appeal by the revenue is directed against the order of the CIT(A), Varanasi dated 2nd March, 1995 for the assessment year 1993-94 on the following grounds :

"1. That the ld. CIT(A) has erred in deleting the addition of Rs. 2,10,000 being the alleged gifts received by the assessee from 10 persons at Rs. 21,000 each. The ld. CIT(A) has failed to appreciate that the gifts were made suddenly and without there being any occasion from as many as 10 persons. He has failed to appreciate that the story or so called gifts represented merely a make-belief and an arrangement for capital build up on the part of the assessee.

2. That the ld. CIT(A) has failed to appreciate that though the gifts were stated to have been made without any consideration and therefore, out of natural love and affection, none of the alleged donors was a close relation of the assessee and all of them reside at Calcutta, whereas the assessee is a resident of Varanasi.

3. That the ld. CIT(A) has not appreciated that the credits in the name of the assessee are nothing but his concealed income and the gifts were shown only to give a colour of genuineness to the effect to bring out his conceal