1982 (7) TMI 112

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... was received by her by way of gifts from the following persons: Rs. 5,000 : from Jamnadas H. Hinduja (father-in-law) Rs. 5,000 : from Madanlal J. Hinduja (brother-in-law) Rs. 5,000 : from Smt. Jayavanthi J. Hinduja (assessee) The share of profits of Smt. Veena R. Hinduja from the firm was Rs. 39,742. Applying the provisions of s. 64 (1) (vi), the ITO included in the total income of th .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... s arisen directly or indirectly from the gift of Rs. 5,000 made by the assessee to her. The ld. counsel for the assessee submitted that Expln. 3 does not apply to s. 64 (1)(vi). Hence, the share income of Smt. Veena R. Hinduja cannot be included in the assessee's total income. 3. We have considered the rival submissions. The Explanations 3 to s. 64 is not made applicable to s. 64 (1) (vi). It i .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X