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1984 (3) TMI 103

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..... years and that they did not represent any income taxable in her hands. In support of this, the assessee had furnished full and complete particulars of the donors from whom she had received these amounts in each year. It was explained that the assessee did not charge or receive anything from her admirers for the spiritual cures, they got from her. The assessee also filed confirmations from her donors in support of her claim. 3. The ITO, however, did not accept the assessee's contentions, as he was of the view that these amounts were paid to the assessee for the spiritual cures or benefits got by the donors from the assessed even though the payments were termed as gifts the regularity of the payments showed that they were received for som .....

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..... e AAC and hence the present appeals to the Tribunal. 6. After having heard the ld. counsel on both sides and carefully considering their submissions in the light of the materials placed before us, we do not find any reason to interfere with the decision of the AAC. There is no dispute that the assessee, who has some spiritual powers of healing, is rendering this service free of charge to those, who seek her help. It was stated before the Department and even before us that the assessee was strictly forbidden by her spiritual masters from demanding or charging for the spiritual services and cures rendered by her to these persons. The declarations or confirmation letters, which has been filed before the Department, and copies of which have .....

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..... mounts to enable the assessee to continue her noble services to the Society without any interruption. 9. In this letter dt. 12th May, 1975, Prem Inder Singh states that he has gifted Rs. 600 as a token of his appreciation of the self-less and noble services rendered by the assessee to the poor people and the simple living of the assessee. Four more letters have been placed before us which also speak in similar terms. We have referred to there of the letters only by way of illustration, to show the high regard and esteem, which the donors have for the assessee, who seems to be rendering self-less service to poor people free of charge by using her spiritual powers. 10. On the above facts and materials, we are satisfied that the receipts .....

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