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2015 (5) TMI 588 - HC - Income TaxUnaccounted bank account - addition to income - AO held that it had not been clarified by the assessee as to why he chose to open an account with Axis Bank, Kapurthala alongwith one Lakhbir Singh by giving his own PAN number. Lakhbir Singh was a joint account holder - Tribunal did not accept the assessee's case regarding the source of sum of ₹ 8.75 lacs - Held that:- This is a pure question of fact. It was a question of appreciation of evidence to be decided on a balance of probabilities. We are unable to hold that findings of the Tribunal are perverse or absurd. It is important to note that the HDFC Bank account was in the joint names of the assessee/appellant and his wife. There is no explanation as to why that amount was deposited in the joint account of Lakhbir Singh. This assumes even greater significance in view of the fact that there is no business relationship even claimed between Lakhbir Singh and appellant/assessee. The appellant claims to have added his name only to accommodate Lakhbir Singh because he did not have PAN card number. Even according to the appellant, Lakhbir Singh was entitled to operate the account. There is no explanation as to why Lakhbir Singh would have been entitled/permitted to operate the account although the amount of ₹ 10 lacs withdrawn from HDFC Bank and alleged to have been deposited with Axis Bank belonged only to the appellant and his wife and in respect whereof Lakhbir Singh had no interest whatsoever. - Decided against assessee.
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