https://www.taxtmi.com/caselaws?id=785872 Interpreting additions under the gift-tax provision, the tribunal found a trust deed amendment replacing Clause 5.2 to be valid and held that beneficiaries are exclusively settlor relatives; therefore the transfer of shares falls within the proviso exception for transfers to relatives and the addition under the provision is deleted. Separately, an alleged receipt of advance tax was treated as an erroneously deposited repayable liability to the settlor, supported by absence of FY 2021-22 ledger entries, subsequent accounting recognition and partial repayment; consequently no income accrued and the Rs. 12 crore addition was disallowed. en-us Wed, 28 Jan 2026 00:00:00 +0530 Mon, 02 Feb 2026 08:20:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785872 Interpreting additions under the gift-tax provision, the tribunal found a trust deed amendment replacing Clause 5.2 to be valid and held that beneficiaries are exclusively settlor relatives; therefore the transfer of shares falls within the proviso exception for transfers to relatives and the addition under the provision is deleted. Separately, an alleged receipt of advance tax was treated as an erroneously deposited repayable liability to the settlor, supported by absence of FY 2021-22 ledger entries, subsequent accounting recognition and partial repayment; consequently no income accrued and the Rs. 12 crore addition was disallowed. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785872