(1.) Through the instant appeal filed under Section 260-A of the Income Tax Act, 1961(for short, 'the Act'), revenue has challenged the order dated 26.05.2006 passed by the Income Tax Appellate Tribunal, Delhi Bench "D"(for brevity, 'the Tribunal'), ordering deletion of additions made by the Assessing Officer and Commissioner of Income Tax(Appeals)[in short, 'CIT (A)'] for the assessment year 2001-02.
(2.) On 16.04.2007, instant appeal was admitted for determining the following substantial question of law:-
(3.) The brief facts of the case are that the wife of the respondent, namely, Smt. Madhu Singla, who died on 31.10.2003, during the assessment proceedings, filed the return on 15.10.2001 for the assessment year 2001-02 showing her income as Rs. 1,99,950/-. She was called upon by the Assessing Officer to explain the following gifts amounting to Rs. 26 lacs received from ten different donors:- <FRM>JUDGEMENT_242_ITR366_2014_1.html</FRM>