Reopening of Tax Assessment Valid Due to Undisclosed Foreign Accounts; Specific Reasons Justified Under Tax Law Sections.

Validity of reopening assessment u/s 147 regarding undisclosed foreign bank account income examined. Non-providing sufficient opportunities and violation of principles of natural justice dismissed as assessee denied ownership initially but later failed to substantiate. Reopening justified under Explanation 2(d) to section 147 deeming foreign asset income as escaped assessment, not based on borrowed satisfaction. Reasons specific, not vague or scanty, quantification not required u/s 149(1)(c) for foreign assets. Reopening within 16-year limitation period upheld. Incriminating materials like statements u/s 132(4) and documentary evidence established ownership of foreign accounts by assessee. Deposits of cheques in assessee's name in accounts ..... .....

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