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ITAT allowed the appeal and deleted additions made under section 56(2)(vii) regarding gifts received after marriage. The assessee received monetary gifts through cheques given during marriage celebrations, but amounts were credited to bank accounts 10-15 days later due to clearing processes. The AO treated these as taxable gifts since credit occurred post-marriage. ITAT held that the expression "on the occasion of marriage" in proviso to section 56(2)(vii) cannot be restrictively interpreted. The tribunal emphasized that when gifts are associated with marriage events, the causal relationship between gift and marriage is determinative, not the timing of account credit. ITAT found the revenue authorities' observations were conjectural without cogent material to disprove documentary evidence. The microscopic interpretation requiring same-day receipt and credit was deemed unrealistic given practical banking procedures.
ITAT allowed the appeal and deleted additions made under section 56(2)(vii) regarding gifts received after marriage. The assessee received monetary gifts through cheques given during marriage celebrations, but amounts were credited to bank accounts 10-15 days later due to clearing processes. The AO treated these as taxable gifts since credit occurred post-marriage. ITAT held that the expression "on the occasion of marriage" in proviso to section 56(2)(vii) cannot be restrictively interpreted. The tribunal emphasized that when gifts are associated with marriage events, the causal relationship between gift and marriage is determinative, not the timing of account credit. ITAT found the revenue authorities' observations were conjectural without cogent material to disprove documentary evidence. The microscopic interpretation requiring same-day receipt and credit was deemed unrealistic given practical banking procedures.
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