- (1.) In both these two income-tax appeals, under Section 260A of the Income Tax Act, 1961 (in short the Act) common question of law is involved. Hence both the appeals are decided by this common judgment.
(2.) The controversy in both the appeals relates to the assessment years 1994-95 and 1995-96 with regard to escaped liability. Brief facts of the case
(3.) The Assessee Respondent filed original return dated 12-3-1996, declaring total income of Rs. 3,04,200. During the course of assessment proceedings of the year 1996-97, it came to light that the Assessee acquired gift for total amount of Rs. 12,51,000, in the name of his minor son from one Shri Abdul Hasan Hanif of Lucknow through his NRE account.;