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TMI Blog2013 (11) TMI 1495X X X X Extracts X X X X X X X X Extracts X X X X ..... e fact of gift of Rs. 1 lakh on 19 different occasions, who happened to be close relatives - For 1993-94, 1994-95 assessment years the interest income earned by the minor was clubbed in the hands of the father - Just because an assessment under Section 153 (3) has not been made or no scrutiny has been made, the income of the minor could not be disbelieved, when the interest was clubbed in the hand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tal and more interest has been shown on lesser capital and the principle of human probabilities as laid down by the Hon'ble Supreme Court in the case of Sumati Dayal vs. CIT 214 ITR 801 has been violated? 2. Whether on the facts and in the circumstances of the case the Tribunal is justified in law in deleting addition of Rs.2,20,000/- in the name of Shri Nawal Jain without appreciating the facts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the factum of gift of Rs. 1 lakh on 19 different occasions, who happened to be close relatives and it is also seen that for 1993-94, 1994-95 assessment years the interest income earned by the minor was clubbed in the hands of the father. Thus, in view of the peculiar facts in A.Y. 1995-96 it cannot be doubted that the assessee Mt. Naval Jain cannot have available with him Rs.2,20,000/-. As such ..... X X X X Extracts X X X X X X X X Extracts X X X X
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