2024 (5) TMI 353

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..... DER 1. Heard Shri Ashish Bansal, learned counsel for the appellant and Shri Krishna Agarwal, learned counsel for the revenue. 2. Present appeal has been filed by the assessee under Section 260A of the Income-Tax Act, 1961 (hereinafter referred as to as 'the Act') arising from the order of Income Tax Appellate Tribunal, Allahabad Bench, Allahabad, dated 22.12.2006 in I.T.A. No.282 (Alld) .....

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..... for generation of the gift, the Tribunal has disbelieved the explanation furnished by the assessee on the preponderance of probability emerging from evidence led by the parties. 6. Insofar as assessment of the income tax is purely a civil proceeding, the test of preponderance of probability applied by the Tribunal cannot be faulted. In the context of gift set up by the assessee, merely because t .....

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