TMI Blog2008 (5) TMI 664X X X X Extracts X X X X X X X X Extracts X X X X ..... sses see - HELD THAT:- We are not convinced that the transaction is above board. We have in particular considered the quantum of the gifts, the fact that there is inadequate material to show the resources or fi nances of the Swiss national: there is no apparent reason for the assessee being showered with gifts by a person who is stated to be only a family friend and that the same family friend has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... agricultural income. Income-tax returns were filed showing an income of ₹ 48,000 in the case of M/s. Ashok Mahindru Sons. The assessee had received a gift from a Swiss national by the name of Ms. Therese Morosini. The gifts received by the assessee and some others are as follows:- Rs. Cheque No. date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Mr. R.K. Mehta 55,00,000 93759 14-09-00 3. In addition to the above, the Swiss national appears to have given gifts to the tune of ₹ 69.50 lakhs to other persons by cheques drawn on the same date that is 14-9-2000. 4. According to all the three authorities below, the assessee was not able to explain the circumstances in whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... how that the transaction is really one which is above board. On the fact of this case, all the three authorities have rejected the explanation of the asses see. 7. We are not convinced that the transaction is above board. We have in particular considered the quantum of the gifts, the fact that there is inadequate material to show the resources or fi nances of the Swiss national: there is no app ..... X X X X Extracts X X X X X X X X Extracts X X X X
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