versus
Section 13 (1) (A) rejecting the extra cash gift of the SCC, claiming that neither the officer at first nor the first appellate authority denied the presence of all three elements which justify the gift only for these reasons. Were rejected because of no blood relationship. the between the donor and the performer who makes the transaction dubious because \ "every rich person can seize his hard earned money with his gift without question \" The estimation of accuracy is not only its nature. And the assessment officer also found the explanation satisfactory by observing that - there is no doubt that the so-called donor has enough money and it is not necessary that every wealthy person gets through their labor. Could make a gift of money, if it were a loan, would have been a position. The observations made by the diagnostic officer made it clear that he did not doubt the nature and source of the ammo. But he doubted his intention to do so because every wealthy person could not take part in his hard-earned property (s) in the absence of any blood relationship from the Assigning Officer. Had said that if it were a loan, the situation would have been one. In the light of such observations by the slightly different and admissible Assigning Officer, the amount claimed by Assessment does not attract the supply of Section 13 (1) (a) of the Income Tax Ordinance, 1979 Department of Action. Was. First Appellate Authority was not sustained by appellate tribunal The order was vacated and the appeal of the SC was accepted
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