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TMI Blog2021 (3) TMI 1297X X X X Extracts X X X X X X X X Extracts X X X X ..... foreign bank account and interest rates thereon. 2. We have heard the Learned Representative of both the parties and perused the findings of the authorities below. 3. The record reveal that earlier Departmental Appeal were dismissed considering it to have low tax effect. However, the Revenue moved an application for rectification of the Order as the case involved is of foreign bank account and as such falls within the exception to the Board Circular. The M.A. of the Revenue was allowed and Departmental Appeal was re-fixed for hearing on merits. 4. In this case, A.O. made addition of Rs. 4,00,008/- on account of interest on money lying in HSBC Bank at Geneva, Switzerland which was held as undisclosed bank account of the assessee. The addi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he deposits in the said bank account as mentioned in the appellate order of the AY 2006-07 in the case of appellant shall have no consequence on it." 5. After considering the rival submissions, we do not find any merit in the Departmental Appeal. The Ld. D.R. relied upon the Order of the A.O. and contended that assessee maintained bank account with HSBC Bank at Geneva, Switzerland and assessee has offered additional income in A.Y. 2006-2007 which was added and the same was the basis for computing the interest in assessment year under appeal. On the other hand, Learned Counsel for the Assessee submitted that in A.Y. 2006-2007 addition was maintained by the Ld. CIT(A) against which no further appeal have been filed. Learned Counsel for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t have earned interest on the same foreign bank account in assessment year under appeal. It was, therefore, clearly support the findings of fact recorded by the Ld. CIT(A) that there were no evidence available with the A.O. to compute the interest earned by the assessee in assessment year under appeal. In the absence of any evidence on record to the effect that assessee maintained any foreign bank account in assessment year under appeal or earned any interest thereon, the Ld. CIT(A) was justified in deleting the addition. We do not find any error in the Order of the Ld. CIT(A) in deleting the addition. The Departmental Appeal fails and is dismissed. 6. In the result, appeal of the Department dismissed. Order pronounced in the open Court.< ..... X X X X Extracts X X X X X X X X Extracts X X X X
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