Addition made U/s. 153A merely on the basis of bank pass book are not sustainable

Nanoomal Gupta Vs ACIT (ITAT Agra)

From the assessee’s return of income, the 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 as per the

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