Soniya Ashokkumar Sachdev v. ITO (2020) 77 ITR 54 (SN) (Pune)(Trib.)

S. 69A : Unexplained money–Cash gift from brother–Stamp paper used for the alleged gift was purchased after two years after declaration of gift-Addition is held to be valid-regarding professional receipts–Addition is deleted.

Tribunal held that the stamp paper used for the gift deed of Rs. 100 was actually purchased two years after the declaration of gift. Such an illegal practice could not be countenanced. The assessee was regularly maintaining a bank account and it was not clear why huge cash of Rs. 11,01,500 was not deposited in her bank account for a period close to six months. Thus the assessee had not proved that she genuinely received gift of Rs. 11,01,500 from her brother. As regards the remaining amount of Rs. 3,03,500, the assessee stated that this was out of her professional receipts redeposited out of withdrawals from the same bank account. Considering the totality of facts and circumstances and also the amount of income declared in the return, the addition of Rs. 3,03,500 was deleted.(AY.2014-15)