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The High Court found that the Income Tax Appellate Tribunal's order regarding the source of cash gifts was perverse and failed to consider the available evidence. The bank statement of the Privy Purse account clearly showed that cheques and cash totaling Rs. 10 lakh were released from this account to the two trusts on various dates. Therefore, the court held that the gift amount was made out of the Privy Purse, requiring further adjudication. The court's decision favored the assessee, overturning the Tribunal's order on this issue.
The High Court found that the Income Tax Appellate Tribunal's order regarding the source of cash gifts was perverse and failed to consider the available evidence. The bank statement of the Privy Purse account clearly showed that cheques and cash totaling Rs. 10 lakh were released from this account to the two trusts on various dates. Therefore, the court held that the gift amount was made out of the Privy Purse, requiring further adjudication. The court's decision favored the assessee, overturning the Tribunal's order on this issue.
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