Addition u/s 68 merely on the basis of Bank Passbook not sustainable

Nanoomal Gupta Vs. ACIT (ITAT Agra)

AO observed that the assessee had shown gifts received of Rs.10,00,000/-, i.e., Rs. 5,00,000/- from Kaushalya Devi, New Delhi and Rs. 5,00,000/- from Shri Shree Bhagwan, New Delhi. The AO required the assessee to furnish the complete details of the donors, their copies of accounts, date and mode of receipt of the gifts and confirmations and to justify the gifts in terms of the identity of the donors, their creditworthiness and the genuineness of the gifts. However, since a

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