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2019 (4) TMI 2003 - AT - Income TaxAddition on the basis of peak balance lying in assessee’s HSBC Private Bank, (Suisse) SA, Geneva - fabricated/manufactured data with some malafide intention - CIT(A) allowed the appeal of the assessee - HELD THAT:- In this case the bone of contention was the source of deposits in HSBC Private Bank, (Suisse) SA, Geneva to the tune of 2,33,92,363/- the peak balance in financial year relevant to A.Y. 2006-07. We find merit in the contentions of the Ld. A.R. that the source of deposit was out of the funds held by the assessee’s husband in Muscat and other countries as assessee’s husband was engaged in the business of construction and builders abroad. The assessee received this money by way of inheritance on the death of her husband in 1988 who expired on 15.07.1988. We further find that the Ld. CIT(A) has allowed the appeal of the assessee after considering all these facts and information record subject to verification of these informations by the AO as AO has passed the assessment order in a hurried manner without examining all these facts. No reason to interfere in the order of Ld. CIT(A) and accordingly we uphold the same by dismissing the appeal of the Revenue.
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