2023 (1) TMI 407 - AT - Income Tax

Addition u/s 68 - undisclosed income in respect of Suisse Bank Account with HSBC Bank Geneva to the returned income - possibility of introduction of unaccounted/undisclosed money in the books of account in the names of relations or third partied - HELD THAT:- Revenue had information that the assessee was having a bank account in HSBC Geneva. The bank account had balance of Rs.USD 4849 and the account also contained the name of the father and mother of the assessee - claim of the assessee that he does not know anything about the said bank account is totally unbelievable. It is beyond the preponderance of human probability that some unknown person will deposit USD 4849 in the name of the assessee in HSBC Geneva bank and the name of the father and mother also be given and the assessee will not have any information about it.

This fully comes under the decision in the case of Sumati Dayal 1995 (3) TMI 3 - SUPREME COURT Hence, the addition in this regard is liable to be sustained.

As regards, the deposit in HSBC London, the assessee has not been able to provide any cogent evidence for the source of deposits. The submissions of the assessee have been without any reliable material. The explanation given by the assessee is only self-serving and has correctly been rejected by the lower authorities. In these circumstances, we do not find any infirmity in the orders of the authorities below and confirm the same. This appeal by the assessee stands dismissed.