DHRUV SANJAY GUPTA ,MUMBAI vs. JCIT, RANGE 27(1), MUMBAI

ITA 5749/MUM/2024Status: DisposedITAT Mumbai20 June 2025AY 2013-14Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)6 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the expression "on the occasion of marriage" in Section 56(2)(vii) cannot be given a restricted meaning. Gifts associated with the event of marriage are covered, regardless of the exact timing of the transaction or fund transfer. The additions made by the Assessing Officer were based on surmises and conjectures.

What were the facts?

The assessee received gifts totalling Rs. 2,11,35,523/- on the occasion of his marriage. Rs. 2 crores were from Shri Anil Kumar Goel and Rs. 11,35,523/- from Shri Siddharth Jatia. The Assessing Officer treated these gifts as sham transactions, arguing they were received after the marriage based on cheque clearing dates and donor's bank balance.

What were the issues?

Whether gifts received on the occasion of marriage, even if cleared or credited after the marriage date, are exempt under Section 56(2)(vii) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 56(2)(vii),Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH MUMBAI

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

Hearing: 07.04.2025Pronounced: 20.06.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by assessee is against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2024-25/1069875490(1), dated 23.10.2024 passed against the assessment order by Joint Commissioner of Income Tax, Range-27(1), Mumbai, u/s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 19.01.2016 for Assessment Year 2013-14. 2 Dhruv Sanjay Gupta AY 2013-14

2.

Grounds taken by the assessee are reproduced as under:

1.

The learned CIT ((Appeals) has erred in law and on the facts of the case in sustaining the addition of Rs. 2 crores u/s. 56(2)(vii)(a) of the Income Tax A

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 56(2)(vii)

All 365 judgments and leading authorities on Section 56(2)(vii) →

Recent GST High Court judgments

Search GST case law →