J.L. Gupta, J. - (1.) THIS is the assessee's appeal under Section 260 -A of the Income Tax Act, 1961 for the assessment year 1990 -91. The assessee viz. Muni Lal Goel, the predecessor -in -interest of the present appellant had filed a return declaring an income of Rs. 31,240/ -. On examination of the matter the Assessing Officer had made an addition of Rs. 12,000/ - on account of household expenses. Another amount of Rs. 1,64.500/ - was added on account of unexplained investment in the capital account of the assessee. Aggrieved by he order the assessee filed an appeal which was dismissed. The second appeal before the Tribunal also met with the same fete. Hence the present appeal.
(2.) MR . Mittal, learned counsel for the appellant contends that gifts worth Rs. 1,64,500/ - had been received from persons staying abroad. The amount was received through different bank drafts. It was deposited in the account of the assessee. Thus, there was no reason for the addition to be made. The matter has been considered at three different levels in the Department. The Income Tax Officer, the appellate authority as well as the Tribunal have come to a concurrent finding against the assessee. It is based on appreciation of evidence produced by the assessee. It is on examination of the evidence that the additions had been upheld. No question of law much less than a substantial question of law arises for consideration.
(3.) LEARNED counsel for the appellant has placed reliance on the decision of their Lordships of Delhi High Court in Commissioner of Income Tax, Delhi (Central -2) v. Sunita Vachani, (1990) : 184 I.T.R. 121 to contend that even strangers can make gifts There is no quarrel with this proposition. A gift can be made by any one. However, the final decision has to be taken on consideration of all relevant facts. The appellant can derive no advantage from the above decision.;