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2022 (6) TMI 1443 - ITAT AMRITSARUnexplained deposit in the foreign bank account - ownership of the alleged bank account or the alleged disputed deposits - as argued assessee was not a beneficiary of the said account and that assessee’s name was struck off from the account when M/s Soverign Holding Private Ltd became owner of this foreign bank account - HELD THAT:- Since, this account was opened by the Sh. Rajinder Singh Chatha as a main beneficial owner of account and that the name of assessee i.e. Joginder Singh Chatha was struck off from the account 11th April, 2004 then by no stretch of imagination assessee can be held liable to pay tax for the deposit in the above said bank account in the A.Y 2006-07 & 2007-08. Over and above, Sh. Rajinder Singh Chatha has paid all the taxes on the outstanding amount in this impugned bank account to the revenue authority of U.K under Specific Disclosure Facility of all the irregularities in UK as per the certificate of C.A. of Sh. Rajinder Singh Chatha i.e. M/s Stonegate Trinity LLP filed in this regard as above. We accept the grievance of the assessee as genuine and accordingly, we hereby delete the addition made by the Ld. Assessing Officer and confirmed by CIT appeals. Decided in favour of assessee.
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