Principal Commissioner of Income-tax-I, Jaipur v. Gulam Farooq Ansari
[Citation -2017-LL-1122-16]

Citation 2017-LL-1122-16
Appellant Name Principal Commissioner of Income-tax-I, Jaipur
Respondent Name Gulam Farooq Ansari
Court HIGH COURT OF RAJASTHAN
Relevant Act Income-tax
Date of Order 22/11/2017
Judgment View Judgment
Keyword Tags co-operative housing society • business connection • confirmation letter • foreign remittance • assessable income • foreign exchange • partnership firm • creditworthiness • returned income • close relative • casus omissus • total income • payments to relative
Bot Summary: Ii) Whether the Tribunal was justified in holding that gifts were not made by nephew but by brother of the assessee which is contrary to record as the bank accounts were admittedly in the name of nephew of the assessee. In pursuant to notice u/s 153A of Income Tax Act, the assessee filed his return on 25-06-2012 declarin the total incom of Rs.9,05,380/-). During the year, the assessee received gift of Rs.24,62,523/- from his brother Gulam Mohemmad Ansari through the bank account of Shri Adil Pervez Ansari and Shri Shah Nawaz Ansari. The assessment of the assessee was completed by AO vide her order dated 31.3.2013 assessing the total income of assessee at Rs. 33,67,903/- as against returned income Rs.9,05,380/- by making following addition in total income:- S.N Particulars Amount(Rs. Treated the gift as received from persons not 24,62,523/- covered within the meaning of relative as given in section 56(2) of Income Tax Act and also treated as not genuine Thus the AO has disallowed the gift only on the basis that person from whose bank account money came to assessee was not covered by the definition of relative u/s 56(2) of the I.T. Act. CIT(A) has confirmed the action of the AO. It is noted that the lower authorities have held that the assessee received the gifts from nephews and section 56(2) defines words Relative which indicate that such relationship is not applicable for gift from nephew accordingly, gift accepted by assessee from nephews does not cover within the provision of that section, besides that the lower authorities have held that the assessee has not proved creditworthiness of the donor and the gift is not genuine as there was no occasion to give the gift, no corresponding gift to other close relative was made by the donor and the assessee has routed his undeclared profit back to his possession in the shape of gift through business connection with his brother. The sister of the assessee has given a written confirmation that the said money was transferred through banking channel on her direction by her son to the assessee. The amount of gift being nominal and fully explained and also in view of the confirmations letter issued by the sister of the assessee that the money was in fact gifted by her and the same was transferred in the account of the assessee by her son on her directions, leaves no doubt that the gift was made by sister of the assessee who falls within the definition of relative as provided u/s 56(2) of the Act.


HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Income Tax Appeal No. 230 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building, Statue Circle, Jaipur (Raj.) ----Appellant Versus Shri Gulam Farooq Ansari, 3261-62, Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur. ----Respondent D.B. Income Tax Appeal No. 231 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building, Statue Circle, Jaipur (Raj.) ----Appellant Versus Shri Gulam Farooq Ansari, 3261-62, Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur ----Respondent D.B. Income Tax Appeal No. 234 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building Statue Circle, Jaipur Raj. ----Appellant Versus Shri Gulam Farooq Ansari 3261-62, Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur. ----Respondent D.B. Income Tax Appeal No. 235 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building Statue Circle, Jaipur Raj. ----Appellant Versus Shri Gulam Farooq Ansari, 3261-62, Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur. (2 of 14) ----Respondent D.B. Income Tax Appeal No. 249 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building Statue Circle, Jaipur Raj. ----Appellant Versus Shri Gulam Farooq Ansari 3261-62, Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur. ----Respondent D.B. Income Tax Appeal No. 254 / 2017 Principal Commissioner of Income Tax-I, New Central Revenue Building Statue Circle, Jaipur Raj. ----Appellant Versus Shri Gulam Farooq Ansari, 3261-62 Majid Mansion, Nawab Ka Chouraha, Ghatgate, Jaipur. ----Respondent _____________________________________________________ For Appellant(s) : Mr. Anuroop Singhi with Mr. Aditya Vijay For Respondent(s) : Mr. Siddharth Ranka with Mr. Muzaffar Iqbal _____________________________________________________ HON'BLE MR. JUSTICE K.S. JHAVERI HON'BLE MR. JUSTICE DEEPAK MAHESHWARI Judgment 22/11/2017 1. In all these appeals common questions of law and facts are involved, hence, they are decided by this common judgment. 2. By way of these appeals, appellant has assailed (3 of 14) judgment and order of Tribunal whereby Tribunal has dismissed appeal of department and partly allowed appeal of assessee. 3. This Court while admitting matters framed following questions of law:- In DBITA No. 230/2017 i) Whether on facts and circumstances of case, Tribunal was justified in deleting addition of Rs. 3,46,548/- made by Assessing Officer and confirmed by CIT(A) u/s 56(2) on account of alleged foreign gifts, received by assessee? In DBITA No. 231/2017 i) Whether on facts and in circumstances of case and in law Tribunal has erred in deleting addition made by Assessing Officer of Rs. 4,58,300/- in case of assessee at 1/3rd of income on basis of transactions recorded in seized record marked as Annexure A-2. ii) Whether on facts and in circumstances of case and in law Hon ble Tribunal has erred deleting addition of Rs. 14,00,000/- on account of undisclosed jewellery found? iii) Whether on facts and circumstances of case and in law Hon ble ITAT has erred in directing AO to compute income on basis of transaction recorded in seized record marked as Annexure A-2 @ 8% of gross receipts instead of treating entire receipts as income? iv) Whether on facts and in circumstances of case and in law Hon ble ITAT has erred in allowing relief of Rs. 1,50,00,000/- out of addition made by AO on account of entries recorded in seized record marked as Annexure A-2 without appreciating facts and circumstances of case? In DBITA No. 234/2017 (4 of 14) i) Whether on facts and in circumstances of case and in law Tribunal has erred in deleting addition made by Assessing Officer of Rs. 1,26,50,240/- in case of assessee at 1/3rd of income on basis of transactions recorded in seized record marked as Annexure A-2. ii) Whether on facts and in circumstances of case and in law Hon ble ITAT has erred in allowing relief of Rs. 11,00,000/- out of addition made by AO on account of entries recorded in seized record marked as Annexure A-2 without appreciating facts and circumstances of case? iii) Whether on facts and circumstances of case and in law Hon ble ITAT has erred in directing AO to compute income on basis of transaction recorded in seized record marked as Annexure A-2 @ 8% of gross receipts instead of treating entire receipts as income? In DBITA No. 235/2017 i) Whether on facts and circumstances of case, Tribunal was justified in deleting addition of Rs. 24,62,523/- made by Assessing Officer and confirmed by CIT(A) u/s 56(2)(vi) on account of alleged foreign gifts, received by assessee.? ii) Whether Tribunal was justified in holding that nephew falls within definition of relative as defined in Section 56(2) of Act. In DBITA No. 249/2017 i) Whether on facts and circumstances of case, Tribunal was justified in deleting addition of Rs. 3,29,436/- made by Assessing Officer and confirmed by CIT(A) u/s 56(2)(vi) on account of alleged foreign gifts, received by assessee. ii) Whether Tribunal was justified in holding that gifts were not made by nephew but by brother of assessee which is contrary to record as bank accounts were admittedly in name of nephew of assessee. In DBITA No. 254/2017 i) Whether on facts and in circumstances of case and in law Tribunal has erred in deleting addition made by Assessing Officer of Rs. 68,75,060/- in case of assessee at 1/3rd of income on basis of transactions recorded (5 of 14) in seized record marked as Annexure A-2. ii) Whether on facts and in circumstances of case and in law Hon ble ITAT has erred in allowing relief of Rs. 1,00,00,000/- out of addition made by AO on account of entries recorded in seized record marked as Annexure A-2 without appreciating facts and circumstances of case? iii) Whether on facts and in circumstances of case and in law Hon ble ITAT has erred in directing AO to compute income on basis of transaction recorded in seized record marked as Annexure A-2 @ 8% of gross receipts instead of treating entire receipts as income? iv) Whether on facts and circumstances of case and in law Hon ble Tribunal has erred in deleting addition made u/s 56(2) of Income Tax Act on account of alleged foreign gifts received by assessee.? 4. Counsel for appellant has taken us to order of AO as well as Tribunal and has relied upon decision of Supreme Court in case of Smt. Tarulata Shyam & Ors. vs. Commissioner of Income Tax (1977) 108 ITR 0345 wherein it has been held as under:- We have given anxious thought to persuasive argument of Mr. Sharma. His arguments, if accepted, will certainly soften rigour of this extremely drastic provision and bring it more in conformity with logic and equity. But language of Sections 2(6A) (e) and 12(1B) is clear and unambiguous. There is no scope for importing into statute words which are not there. Such import would be, not to construe, but to amend statute. Even if there be casus omissus, defect can be remedied only by legislation and not by judicial interpretation. 35. To us, there appears no justification to depart from normal rule of construction according to which intention of legislature is primarily to be gathered from words used in statute. It will be well to recall words of Rowlatt J, in Cape Brandy Syndicate v. I.R.C. (1) at p. 61 that "in taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is (6 of 14) no enquiry about tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at language used". Once it is shown that case of assessee comes within letter of law, he must be taxed, however great hardship may appear to judicial mind to be. 4.1. He has further relied upon decision of Supreme Court in case of Commissioner of Income Tax-III vs. Calcutta Knitwears, Ludhiana (2014) 6 SCC 444 wherein it has been held as under:- 23. Lord Granworth in Grundy v. Pinniger (1852) 1 LJ Ch 405 has observed that: To adhere as closely as possible to literal meaning of words used, is cardinal rule from which if we de-part we launch into sea of difficulties which it is not easy to fathom. That is to say, once literal rule is departed, then any number of interpretations can be put to statutory provision, each Judge having free play to put his own interpretation as he likes. This would be destructive of edifice of fiscal legislations which impose economic duties and sanctions. 24. In taxing statutes, even if literal interpretation results in hardship or inconvenience, it has to be followed (G.P. Singh's Principles of Statutory Interpretations, 12th Ed, 2010, Lexis Nexis Butterworths Wadhwa Nagpur; Bennion on Statutory Interpretation, 5th Ed., Lexis Nexis, p.863; Vepa P. Sarathi, Interpretation of Statutes, 5th Ed., Easter Book Company, Chapter VIII, Taxing Statutes). This Court in CIT v. Keshab Chandra Mandal MANU/SC/0021/1950 : AIR 1950 SC 265 has held that hardship or inconvenience cannot alter meaning of language employed by legislature if such meaning is clear and apparent. Hence departure from literal rule should only be done in very rare cases, and ordinarily there should be judicial restraint to do so. (Pandian Chemicals Ltd. v. C.I.T. MANU/SC/0487/2003 : 2003 (5) SCC 590, Narsiruddin v. Sita Ram Agarwal MANU/SC/0100/2003 : AIR 2003 SC 1543, Bhaiji v. Sub-Divisional Officer, Thandla MANU/SC/1154/2002 : 2003 (1) SCC 692, J.P. Bansal v. State of Rajasthan and Anr. MANU/SC/0235/2003 : AIR 2003 SC 1405, State of Jharkhand and Anr. v. Govind Singh (7 of 14) MANU/SC/1133/2004 : JT 2004 (10) SC 349, Jinia Keotin v. K.S. Manjhi MANU/SC/1192/2002 : 2003 (1) SCC 730, Shiv Shakti Co-operative Housing Society v. Swaraj Developers MANU/SC/0335/2003 : AIR 2003 SC 2434, Grasim Industries Limited v. Collector of Customs MANU/SC/0256/2002 : 2002 (4) SCC 297 and Union of India v. Hamsoli Devi MANU/SC/0768/2002 : 2002 (7) SCC 273) 25. Australian High Court in Federal Commissioner of Taxation v. Westraders Pty Ltd. (1980) 144 CLR 55 considered scope of Section 36A of Income Tax Assessment Act, 1936(Cth), which on literal interpretation allowed taxpayer to make profit and still claim loss for tax purposes. Commissioner argued taxpayer's conduct amounted to tax avoidance scheme and should therefore be disallowed under Section 260 of Income Tax Assessment Act, 1936(Cth). Court held that under literal interpretation Section 36A could apply to allow taxpayer to claim loss. Barwick CJ, speaking for majority relied on decision in Inland Revenue Commissioners v. Westminster (Duke) [1936] AC 1 which advocated literal approach be applied when interpreting taxation legislation and stated following: It is for Parliament to specify, and to do so, in my opinion, as far as language will permit, with unambiguous clarity, circumstances which will attract obligation on part of citizen to pay tax. function of court is to interpret and apply language in which Parliament has specified those circumstances. court is to do so by determining meaning of words employed by Parliament according to intention of Parliament which is discoverable from language used by Parliament. It is not for court to mould or to attempt to mould language of statute so as to produce some result which it might be thought Parliament may have intended to achieve, though not expressed in actual language employed. 26. In Cooper Brookes (Wollongong) Pty Ltd. v. Federal Commissioner of Taxation (1981) 147 CLR 297 it is held that in taxing statute if language is unambiguous, departing from literal approach 'may lead judges to put their own ideas of justice or social policy in place of words of statute'. Similar view was espoused in C and J Clark Ltd. v. (8 of 14) Inland Revenue Commissioners [1975] 1 WLR 413 and BP Refinery (Westernport) Pty Ltd. v. Hastings Shire (1977) 180 CLR 266. 27. In Hepples v. FCT (1991) 173 CLR 492, High Court of Australia unequivocally favoured principle that taxation legislation should be subject to strict literal interpretation and opined that such approach was supported by 'common sense'. Therein, taxpayer, on ceasing to be employed, was paid $40,000 by his employer in exchange for taxpayer agreeing that he would not carry on or be interested in certain businesses and would not divulge any trade secrets. issue before Court was whether or not such payment would form part of taxpayer's assessable income for purposes of Income Tax Assessment Act, 1936(Cth). It was held that since Act did not provide for such payments to form part of taxpayer's assessable income, payment would not be assessable. 28. This Court in Tata Consultancy Services v. State of Andhra Pradesh has ascribed plain meaning to terms computer and computer programme in fiscal statute and reiterating proposition laid down in Inland Revenue Commissioner case (supra), observed that court should not be over zealous in searching ambiguities or obscurities in words which are plain. 29. In Prakash Nath Khanna v. C.I.T. MANU/SC/0134/2004 : 2004 (9) SCC 686, this Court has explained that language employed in statute is determinative factor of legislative intent. legislature is presumed to have made no mistake. presumption is that it intended to say what it has said. Assuming there is defect or omission in words used by legislature, Court cannot correct or make up deficiency. Where legislative intent is clear from language, Court should give effect to it (Delhi Financial Corporation v. Rajiv Anand MANU/SC/1105/2004 : 2004 (11) SCC 625; Government of Andhra Pradesh v. Road Rollers Owners Welfare Association MANU/SC/0653/2004 : 2004 (6) SCC 210). 30. In B. Premanand and Ors. v. Mohan Koikal and Ors. MANU/SC/0249/2011 : (2011) 4 SCC 266 this Court has observed as follows: 24. literal rule of interpretation really means that there should be no interpretation. In other (9 of 14) words, we should read statute as it is, without distorting or twisting its language. We may mention here that literal rule of interpretation is not only followed by Judges and lawyers, but it is also followed by lay man in his ordinary life. To give illustration, if person says "this is pencil", then he means that it is pencil; and it is not that when he says that object is pencil, he means that it is horse, donkey or elephant. In other words, literal rule of interpretation simply means that we mean what we say and we say what we mean. If we do not follow literal rule of interpretation, social life will become impossible, and we will not understand each other. If we say that certain object is book, then we mean it is book. If we say it is book, but we mean it is horse, table or elephant, then we will not be able to communicate with each other. Life will become impossible. Hence, meaning of literal rule of interpretation is simply that we mean what we say and we say what we mean. 31. Thus, language of taxing statute should ordinarily be read understood in sense in which it is harmonious with object of statute to effectuate legislative animation. taxing statute should be strictly construed; common sense approach, equity, logic, ethics and morality have no role to play. Nothing is to be read in, nothing is to be implied; one can only look fairly at language used and nothing more and nothing less. 5. Counsel for respondent Mr. Ranka has supported order of Tribunal and contended that Tribunal while considering matters has rightly interpreted in para 3.4 & 4 observing as under:- 3.4 We have heard rival contentions and perused materials available on record. Brief facts of case are that assessee is individual. assessee is partner in firm M/s N.N. Jewellers. assessee was not carrying any regular business activities in his personal capacity. department carried out search & seizure operations over assessee group on 22-09-2010 (Copy of Panchanama at PB Page 1 to 4). 4. (10 of 14) case of assessee was centralized at Central Circle-3, Jaipur. Notice u/s 153A was issued on 15-12-2011 (Copy at PB Page 76). In pursuant to notice u/s 153A of Income Tax Act, assessee filed his return on 25-06-2012 declarin total incom of Rs.9,05,380/-). During year, assessee received gift of Rs.24,62,523/- from his brother Gulam Mohemmad Ansari through bank account of Shri Adil Pervez Ansari (son of brother) and Shri Shah Nawaz Ansari (Son of sister). Shri Gulam Mohemmad Ansari is NRI residing in Hong Kong ad doing business of gem stones. assessee filed copy of confirmation letter of gift received, copy of profit tax assessment of Shri Gulam Mohemmad Ansari filed in Hong Kong and documents in support of identity and creditworthiness of donor. However, AO held taht gifts were received from persons not covered within meaning of relative as given in section 56(2) of Income Tax Act and also treated as not genuine and added same to income of assessee. assessment of assessee was completed by AO vide her order dated 31.3.2013 assessing total income of assessee at Rs. 33,67,903/- as against returned income Rs.9,05,380/- by making following addition in total income:- S.N Particulars Amount(Rs.) o. 1. Treated gift as received from persons not 24,62,523/- covered within meaning of relative as given in section 56(2) of Income Tax Act and also treated as not genuine Thus AO has disallowed gift only on basis that person from whose bank account money came to assessee was not covered by definition of relative u/s 56(2) of I.T. Act. In first appeal, ld. CIT(A) has confirmed action of AO. It is noted that lower authorities have held that assessee received gifts from nephews and section 56(2) defines words "Relative" which indicate that such relationship is not applicable for gift from nephew accordingly, gift accepted by assessee from nephews does not cover within (11 of 14) provision of that section, besides that lower authorities have held that assessee has not proved creditworthiness of donor and gift is not genuine as there was no occasion to give gift, no corresponding gift to other close relative was made by donor and assessee has routed his undeclared profit back to his possession in shape of gift through business connection with his brother. Further, assessee received gift when he was in need of funds for investment in properties. It is observed taht Shri Gulam Mohd Ansari is brother of assessee and doing business in Hong Kong in name of M/s Evergreen Exports. assessee has proved identity of donor by furnishing copy of passport and id proof of Shri Gulam Mohd Ansari (donor), and capacity of donor by submitting profit tax assessment of Shri Gukam Mohd Ansari for AY 05-06 to AY 11-12 (Copy at PB Page 95-108) assessment made by Inland Revenue Department of Hong Kong. genuineness of gift is proved by bank statement and Bank Advice against foreign remittance. assessee has submitted confirmation of Shri Gulam Mohd Ansari donor stating that gift was actually made by him though bank account of his son/son of sister maintained by him and fund deposited in their bank account were deposited by him out of his own income/savings. Further assessee submitted copy of Bank advice against foreign remittance wherein it has been mentioned that reason of transfer is Gift and further mentioned in bank advice "by order of GM Ansari". This noting on bank advice/TT is sufficient to show that gift was made by Shri Gulam Mohd Ansari. Therefore, it cannot be held taht gift was made by neqhew of assessee. assessee has sucessfully shown that gift was made by his brother not by nephew so gift is covered proviso to clause (vi) of section 56(2) of Income Tax Act. It is noted that ITAT Coordinate Bench of Chandigarh in case of Shri Ramesh Garg Vs. ACIT, Circle-5(1), Chandigarh in ITA No. 29/Chd./2013 vide order dated 13.05.2014 has held that gift received from nephew (son of sister) on direction of sister falls within definition of relatives as provided u/s 56(2) of Act. relevant para of ITAT Chandigarh Bench in ITA No. 29/Chd/2013 is as under:- "7. We have considered rival submission of ld. Representative of both parties. It is admitted fact amount in question had been transferred through banking channel. There is no (12 of 14) doubt about identity and financial capacity of transfer of amount. It is also admitted fact that transfer of money was from son of sister of assessee. sister of assessee has given written confirmation that said money was transferred through banking channel on her direction by her son to assessee. amount involved in dispute is also nominal amount which is not unusually high. It is in normal course of relations that mother asks her son to do certain activities relating to financial matter also due to old age or other related compulsions. Similarly, in our society son also feels obligation to respect and obey orders of mother. amount of gift being nominal and fully explained and also in view of confirmations letter issued by sister of assessee that money was in fact gifted by her and same was transferred in account of assessee by her son on her directions, leaves no doubt that gift was made by sister of assessee who falls within definition of relative as provided u/s 56(2) (vi) of Act. 8. In view of above observations, impugned order of CIT(A) is hereby set aside and disallowance in question is ordered to be deleted." It is also worthwhile to mention that ld. CIT(A) has rejected confirmation of donor by mentioning that confirmation is not notorized for which there is no law under which notarization is mandatory for valid confirmation. It is also notable that there is no need to prove source of source for which following Hon'ble Courts have given verdict in favour of assessee 1. CIT Vs Orissa Corporation (P) Ltd (1986) 159 ITR 79 (SC) 2. CIT Vs Heera Lal Chagan Lal Tank (2002) 157 ITR 281 (Raj) 3. Aravali Trading Co. Vs. Income Tax Officer (2008) 8 DTR (Raj) 199. It is also noted that department has carried out search operation and no document was found to show that assessee has transferred money to donor for obtaining bogus gift. department has seized several loose papers and dairy from possession of assessee and AO has not brought to notice any entry showing transfer of cash to donor against gift received by him from his brother. Further It is not necessary to make valid gift, (13 of 14) there should be corresponding gift by donor to his other close relatives. It is also motable that gift should be only on some specific occasion which may be made at any time. It is also noted from available records that AO has not brought any positive material to show that assessee has routed his undeclared profit back to his possession in shape of gift through business connection with his brother. partnership firm of assessee is doing business of exports/imports of gem stones which is always subject to monitoring of custom authorities and payments are always routed through banking channels. In view of above facts and circumstancs of case, we do not concur with views of ld. CIT(A) and direct to delete addition of Rs.24,62,523/- made by lower authorities. Thus Ground No.1 and 2 of assessee is allowed. 4.1 In assessment year 2007-08, Ground No. 3 of assessee is regarding not allowing benefit of telescoping, recycling and rotation of fund out of income of partnership firm of M/s. N.N. Jewellers. 4.2 We have heard rival contentions and perused materials available on record. Ground No.3 of assessee is infructuous as no addition has been sustained on account of gift. Thus Ground No.3 of assessee is dismissed. 6. Taking into consideration factual matrix, it is contended that Tribunal has rightly held in favour of assessee. 7. We have heard counsel for both sides. 8. Looking to definition of relative, amount which has been added by AO is just and proper, though Tribunal has while interpreting extended meaning of gift by including gift made by brother which was transferred from bank account of nephew. 9. In that view of matter, amount transferred by nephew as gift to brother of father (Uncle) cannot be (14 of 14) exempted. Thus, interpretation put forth by Tribunal is required to be reversed and same is reversed. 10. This issue is decided in favour of revenue against assessee. 11. Counsels has taken us to order of CIT(A) as well as Tribunal and contended that looking to facts which have been decided by Tribunal, amount which was received from foreign exchange from brother is required to be accepted under Section 56(2) of Income Tax Act. We are in complete agreement with finding recorded by Tribunal in this regard hence, issue is decided in favour of assessee. 12. After hearing counsels, on other issues, we do not find any ground to interfere with finding arrived at by tribunal. 13. In that view of matter, issue regarding gift from Nephew is decided against assessee and all other issues are decided in favour of assessee and against department. 14. appeals stand disposed off. (DEEPAK MAHESHWARI)J. (K.S. JHAVERI)J. A.Sharma/ Principal Commissioner of Income-tax-I, Jaipur v. Gulam Farooq Ansari
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