Love and affection can be reflected by frequent acquaintance, mutual exchange of gifts, mutual help to each other

RELEVANT PARAGRAPH 19. We have considered the rival submissions and perused the material on record. In our considered view inferences drawn by the authorities below are not sustainable in law. The grounds on which the A.O. has added the amount of gift as assessee’s income are summarized by us in para 12. We do not agree that the persons showing income of Rs.80,000 to Rs. 1,50,000 per annum would be persons of no means or low means. These donors are clearly identifiable and they are assessed to tax. They had appeared before the A.O. and given their statements to the A.O. Therefore, there ...