- (1.) The Revenue is in appeal impugning the order dated July 30, 2003, passed by the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for brevity, "the Tribunal"), in I.T.A. No. 112(ASR)/2002 and 193(ASR)/2002 relating to the assessment year 1998-99. The Revenue had raised two substantial questions of law, pertaining to the order of the Tribunal regarding foreign gifts of Rs. 5,00,000 and Rs. 9,58,759. It has been pointed that the question regarding the transaction of Rs. 5,00,000 made by Pritam Singh in favour of the assessee was remanded by the Tribunal to the Assessing Officer and is pending before the Commissioner of Income-tax (Appeals) and it does not survive in the present appeal.
(2.) On May 12, 2006, the instant appeal was admitted only to consider the second question of law, which reads as under: "Whether, on the facts and in the circumstances of case, the hon'ble Income-tax Appellate Tribunal was justified in law in accepting the genuineness of gifts at Rs. 9,58,759 especially when there was no occasion to receive huge gifts from unrelated persons?"
(3.) In order to appreciate the controversy in its right perspective, the facts of the case are noticed.;