9911796707
TMI Blog2024 (5) TMI 353X X X X Extracts X X X X X X X X Extracts X X X X ..... lved deep into the matter and discovered that there was no pre-existing relationship or circumstances disclosed as may have given rise to any gift to the assessee. Appellant is a well to do person whereas the donors were persons of modest means. In absence of any relationship shown or basis disclosed for generation of the gift, the Tribunal has disbelieved the explanation furnished by the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disbelieving the claim on the basis of holistic consideration of the material before the Tribunal. Its findings are pure findings of fact. They do not give rise to any substantial question of law. - Hon'ble Saumitra Dayal Singh And Hon'ble Donadi Ramesh JJ. For the Appellant : S.K. Garg, Ashish Bansal, Krishna Agarawal For the Respondent : S.C., Praveen Kumar ORDER 1. Heard Shri Ashish B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /-. 4. The Tribunal had delved deep into the matter and discovered that there was no pre-existing relationship or circumstances disclosed as may have given rise to any gift to the assessee. 5. As to status, it has been noticed, the appellant is a well to do person whereas the donors were persons of modest means. In absence of any relationship shown or basis disclosed for generation of the gift, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... money, we do not find any defect in the course adopted by the Tribunal in disbelieving the claim on the basis of holistic consideration of the material before the Tribunal. Its findings are pure findings of fact. They do not give rise to any substantial question of law. Though the appeal had been admitted on the questions of law as proposed, yet, on consideration made above, we find no substantial ..... X X X X Extracts X X X X X X X X Extracts X X X X
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