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TMI Blog2007 (7) TMI 40X X X X Extracts X X X X X X X X Extracts X X X X ..... - - - Dated:- 13-7-2007 - JUDGMENT The judgment of the court was delivered by 1 MADAN B. LOKUR, J. The Assessee is aggrieved by an order dated 8th September, 2006 passed bythe Income Tax Appellate Tribunal, Delhi Bench 'C' in ITA No.3495(Del)/2004relevant for the assessment year 2001-02. 2. The Assessee claims to have received two gifts from abroad. One gift was from Mr. P.B. Bhardwaj ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the donors had been established and consequently it was submitted that the Assessing Officer should not have come to the conclusion that the gifts were bogus. The CIT (A) did not agree with the view canvassed by the Assessee and dismissed the appeal. Similarly, the Tribunal also dismissed the appeal of the Assessee and that is how we are required to deal with this appeal under Section 260A of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts of this case that the two donors had absolutely no connection with the Assessee and they made gifts to the Assessee only because he needed money to buy a house and they wanted to help him. It appears to us that this is not only quite unusual but also quite unnatural. It sounds rather incredible that a complete stranger would want to gift lakhs of rupees to a person only because that person w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see offers an explanation then, in the opinion of the Assessing Officer, it is not satisfactory it is only then that the sum so credited may be charged to income tax as the income of an Assessee. 7. The Supreme Court considered the expression "the assessee offers no explanation" and observed that what it means is that the Assessee offers no proper, reasonable and acceptable explanation in the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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