ground raised by assessee in this appeal is one which is not normally raised because it cannot legally be raised. ground of assessee is that gift made by Shri Sain Dass in sum of Rs. 10,000 to Shri Jatinder Kumar ought to have been considered as genuine gift and it must have been subjected to gift-tax. 2. Facts in background are that one Shri Sain Dass, who was agriculturist owned 18 acres of land in his own name besides other 54 acres held by his joint family, is said to have given Rs. 10,000 as gift to Shri Jatinder Kumar. Strangely enough, in affidavit Shri Sain Dass submitted that Shri Jatinder Kumar is his relative but when he was examined on oath by GTO, he submitted that Gurcharan Das, father of Shri Jatinder Kumar was not related to him. GTO naturally looking to facts on record considered said gift to be ingenuine and framed assessment as protective measure. assessee came before AAC, who confirmed action of GTO observing that gift does not appear to be bona fide. 3. assessee has raised following grounds of appeal before us against order of AAC: "1. That learned Appellate Assistant Commissioner has erred in law as well as on facts in upholding gift of Rs. 10,000 made by appellant to be not genuine gift which is arbitrary and unjustified. 2. That merely because there does not exist any relationship between donor and donee, does not render gift to be invalid or ingenuine, and as such, it is wrong to hold that gift is not bona fide gift. 3. That order of learned Appellate Assistant Commissioner is erroneous, arbitrary, opposed to law and facts of case and is, thus, untenable". learned counsel for assessee while addressing us submitted that if we go through definition of gift for its bona fide, it has to be out of love and affection and without consideration and there was nothing wrong with gift made by Shri Sain Dass in favour of Shri Jatinder Kumar. According to him, discrepancy in statement made in affidavit by assessee could not be fatal to assessee's claim. On query from Bench as to under what section order of GTO could be appealed against before AAC, learned counsel for assessee read at length section 22 of Gift-tax Act, 1958 ('the Act') and when he did not find any provision under which such order could be appealed against he submitted that so far as Tribunal was concerned, he was in appeal against order of AAC. When it was put to him that matter of jurisdiction being purely legal can be raised at any stage and by any one, order passed by AAC becomes invalid as it is order without any jurisdiction. learned departmental representative, on his part, submitted that this is device for avoidance of tax which is sang in this case and looking to absence of relationship between donor and donee, GTO was justified in giving finding as he did. He relied on Supreme Court's judgment in case of Juggilal Kamlapat v. CIT [1969] 73 ITR 702. He also relied on Punjab and Haryana High Court's decision in case of Lall Chand Kalra v. CIT [1981] 6 TAXMAN 171. 4. After taking into consideration rival submissions, we are unable to interfere with order of AAC on basis of Punjab and Haryana High Court's decision in case of Lall Chand Kalra (supra). In that case, gift was identical by donor who was agriculturist but was not related to donee and in that case contention of assessee was that donor being stranger to donee, there was no reason why he should have made gift to assessee. Besides, dispute was also regarding means of donor. In that context, their Lordships held that, 'even if two donors were found to be men of means, this finding of Tribunal that gifts were not genuine could not be said to be vitiated because findings of Tribunal regarding nature of gifts could be sustained on other reasons given by it for disbelieving genuineness of alleged gifts'. There is no dispute about fact that revenue can pierce veil in tax matters as was held by Supreme Court in case of Juggilal Kamlapat (supra) though that was matter pertaining to corporation. Even on basis of jurisdiction, when we go through section 22, we find that there did not arise any grievance out of order of GTO, which could entitle assessee donor to come forward in appeal. order of AAC due to lack of jurisdiction has got to be annulled but at same time, order of ITO would stand, so far as merit of matter is concerned, as it is covered by Punjab and Haryana High Court's decision. AAC in his order confirmed order of GTO and by our decision, order of GTO would hold field, but due to correct application of law, remedy resorted to by assessee in form of first appeal before AAC was not proper. Anyway, as stated above, Lall Chand Kalra's case (supra) on merits is against assessee and, therefore, order of GTO survives. 5. In result, assessee's appeal is dismissed subject to above observations. *** SAIN DASS v. GIFT TAX OFFICER