Mere receipt of amount through banking channels is by itself not sufficient to prove genuineness of a gift.
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Genuineness of the gift transactions cannot be determined without looking into the human probability aspects, surrounding circumstances such as relationship of the donor and donee and if assessee fails to establish any of these facts, the gift transaction cannot be treated as genuine
ITAT, ‘C’ BENCH , AHMEDABAD
Dinesh Babulal Thakkar
v.
ACIT
ITA Nos. 4434 & 4435/Ahd/2006
March 31, 2010
