Addition made u/s 153A on account of undisclosed foreign bank ...
Imputed Income Addition Rejected Due to Closed Account; Jewelry Gift Evidence Partially Reduces Taxpayer's Liability.
October 25, 2024
Case Laws Income Tax AT
Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing unique code assigned for operation of foreign bank account - Revenue possessed overwhelming material indicating assessee held foreign bank account which assessee refused to confirm by not providing consent waiver form citing self-incrimination plea rejected as not maintainable - adverse inference drawn from assessee's conduct and undertaking - addition of imputed interest income not sustainable as bank account closed before relevant period. Addition on unexplained investment in jewelry - part addition deleted for jewelry received as wedding gifts with supporting evidence, balance addition confirmed for lack of proper details regarding jewelry claimed as received on children's birthdays.
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