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2021 (10) TMI 82 - AT - Income TaxAddition on account of interest in the HSBC Geneva bank account - AO has computed the interest by taking the last known credit balance in the bank account as on May, 2006 - HELD THAT:- As after the May, 2006 there was no material available with the Assessing Officer to show whether any credit balance was available in the said bank account in the subsequent year and particularly for the year under consideration. The Assessing Officer has not disputed the fact that the there is no bank statement available or any other information to show the status of existence or foreclosure of the bank account as on 31.03.2014. Therefore, the Assessing Officer has made addition on presumptive interest income of the assessee. DR has not disputed the facts as recorded by the Ld. CIT(A) that the Assessing Officer has made the addition without any material to show any interest income of the assessee from the alleged HSBC Geneva bank account - As relying on own case [2016 (4) TMI 668 - ITAT DELHI] AO had not brought on record any evidence to link the money brought into India or kept in foreign accounts by the assessee have a link with any Indian defence contract payment. The income has not accrued or arisen in India. - Decided against revenue. Unexplained deposits in the ICICI Bank London - HELD THAT:- Assessing Officer was not sure about the year in which these deposits were made in those bank accounts. Finally, the Assessing Officer has held that in the absence of any required information amount appearing in the Column No.9 of the table showing the difference of the amount already added to the income of the assessee in the preceding Assessment Years to be added as income for the year under consideration. Assessing Officer has also recorded the fact that the status of the assessee as NRI during those years is not finally settled as pending before the Hon’ble Supreme Court. Now the said dispute of NRI status is finally settled and the order of the Hon’ble jurisdictional High Court has been upheld by the Hon’ble Supreme Court as pointed out by the Ld. AR which was not disputed by the Ld. DR. As relying on own case [2016 (4) TMI 668 - ITAT DELHI] issue decided in favour of assessee.
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