[Civil Appeal No. 3914 of 2010]. [Civil Appeal No. 3915 of 2010]. Civil Appeal No. 3914/2010 (Assessee: Satya Nand Munjal) and Civil Appeal No. 3915/2010 (Assessee: Om Prakash Munjal) arise out of G.T.A. No. 3/2001 and G.T.A. No. 2/2001 respectively both decided by the High Court of Punjab & Haryana on 17th December, 2008. The relevant Assessment Year is 1989-90. At the instance of the Revenue, the High Court was called upon to decide the following common substantial question of law:- "Whether, on the facts and in the circumstances of the case, the ITAT was right in law in quashing the gift-tax assessment in the assessee's case. "The High Court set aside the order of the Income Tax Appellate Tribunal (the Tribunal) and held in favour of the Commissioner of Gift Tax by upholding the assessment order. It is in these circumstances that the assessee is now before us. For convenience, we refer to the facts in the case of Satya Nand Munjal.
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