2026 (3) TMI 392

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....: P. Pavan Kumar Rao. Counsel for the Respondent(S): Y.N. Vivekananda. ORDER PER HON'BLE SRI JUSTICE R. RAGHUNANDAN RAO 1. Heard Sri P. Pavan Kumar Rao, learned counsel appearing for the appellant, and Sri Y.N. Vivekananda, learned Standing Counsel appearing for the respondents. 2. This appeal is filed against the judgment of the Income Tax Appellate Tribunal Hyderabad 'B' B....

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....nt that she had received cash gifts of Rs.1.83 crores. 4. Aggrieved by the said order of assessment, the appellant approached the Commissioner of Income Tax, Appeal, Tirupathi. The Commissioner accepted the explanation given by the appellant as to how she had received such cash gifts and allowed her appeal. Against this order, dated 28.11.2018, the department went in appeal before the Appellate....

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.....83 crores on 05.03.2014, from her grandmother and that this gift, though received on 05.03.2014, was wrongfully posted in the books of account on 31.03.2014. The appellant was called upon to explain the source of income of the grandmother of the appellant, who is said to have given such a gift to the appellant. In response, the appellant contended that her grandmother had withdrawn Rs.3.5 crores ....

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....of Income Tax had held that the objections of the assessing officer were not justified as a declaration had been given by the grandmother of the appellant regarding the gift made by her and the same should be accepted. The Appellate Tribunal did not accept this view of the Commissioner and had held that the alleged gift of Rs.1.83 crores in cash, to the appellant cannot be believed as the source o....