Gift backed by donor confirmation and bank proof cannot sustain an unexplained investment addition under income-tax law.

Donor confirmation and bank evidence can satisfactorily explain a gift for income-tax purposes, defeating an addition for unexplained investment under section 69. The ITAT found that the assessee proved the donor-mother's identity, the family relationship, and the availability of funds through bank statements showing a credit followed by withdrawal immediately before the gift. Because the Revenue produced no material to rebut that documentary evidence, the source of the gifted amount was treated as explained and the section 69 addition was deleted.

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Issues: Whether the addition of Rs. 5,71,944 under section 69 of the Income-tax Act, 1961, as unexplained investment on account of a gift received from the assessee's mother was sustainable.

Analysis: The assessee produced a confirmation from the donor-mother acknowledging the gift and her bank statements showing a credit of Rs. 8,42,000 followed by withdrawal of Rs. 8,00,000 immediately before the gift. The identity of the donor, the relationship between the donor and the assessee, and the availability of funds in the donor's hands were found to be established. The Revenue brought no material to rebut the documentary evidence showing that the impugned amount was explained by the gift.

Conclusion: The addition under section 69 of the Income-tax Act, 1961, was held to be unsustainable and was directed to be deleted in favour of the assessee.

Ratio Decidendi: Once the assessee furnishes a donor confirmation and bank evidence showing sufficient funds in the donor's account immediately before the gift, the source of the gifted amount stands satisfactorily explained and an addition for unexplained investment under section 69 cannot be sustained.

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