submissions made by the ld. D.R. :-
1. In case the gifts were invalid, then the right to the moneys still vested in the donors ... already accepted the validity of the gifts.
2. Even if the gifts were invalid, the source was still linked to the donors there being nothing
gift. He, therefore, held that totality of circumstances proved invalidity of the gift given to the assessee, being a compensatory receipt for which equivalent amount ... adequate compensation equivalent to the amount of gift to Shri Bhangu and, therefore, the gift was invalid. He referred to the portion
grant of gift to the assessee, did not absolve the assessee from
proving that the person making the gift had financial capacity ... gifts. The CIT
(Appeals) upheld the order of the Assessing Officer in doubting the
entries in the bank account and holding the gift as invalid
invalid or shall be deemed to be invalid merely by reason of any mistake, defect or omission in such return of gifts, assessment, notice, summons ... provision of Section 41C of the Gift-tax Act also state that the proceedings do not become invalid in the eventuality mentioned above.
Submitted please
Officer. The learned D.R. argued that it is a case of invalid and illegal trust formed as a device for tax evasion to which ... Income-tax Officer, it would be invalid for affecting a genuine transfer attracting gift-tax and also giving bona fide standing
between the donor and the donee, does not render the gift to be invalid or ingenuine, and as such, it is wrong to hold that ... gift is not a bona fide gift.
3. That the order of the learned Appellate Assistant Commissioner is erroneous, arbitrary, opposed to law and facts
contended that notice should have been issued Under Section 19 of the Gift Tax Act.
7. It is further not made clear in the notice ... Gift-tax Act . Notice to assessee was issued after statement of the assessee was recorded that she had received property in gift from her mother
M/S Satwant Agro Engineers, ... vs Dcit, Central Circle, Patiala on 3 May, 2024
आयकर
such purchases. No addition could be made
on the basis of such invalid document. The property was purchased
through sale deed only and the payment ... since the addition of alleged on-money for Rs.230
Lacs and gift of Rs.88 Lacs and transfer of Rs.13 Lacs
such purchases. No addition could be made
on the basis of such invalid document. The property was purchased
through sale deed only and the payment ... since the addition of alleged on-money for Rs.230
Lacs and gift of Rs.88 Lacs and transfer of Rs.13 Lacs
