Gift cannot be said ingenuine if identity and relationship with donor established

Brief Facts

1. Arjun C Waney settled in United States, gifted an aggregate of $3 lakhs vide a letter dated 10.1.1984 to one Sh. Ashwani Suri and directed by letter written to the beneficiary Mr. Ashwani Suri to distribute the sum received in different proportions and one of the receiver is present assessee Mr. Ramesh Suri, who has received US Dollors 16000 equivalent to Rs 184860/-as stated in the letter.

2. Ashwani Suri, the original donee complied with the directions of the donor contained in the letter and transmitted the relevant amounts to each of the beneficiaries named in the said letter. These transactions were made out by each of the beneficiaries

3. The revenue sought to bring to tax these amounts, on the plea that the sources of income were undisclosed, and were liable to be added back under Section 68, since they were not genuine gifts.

Issue

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