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2022 (12) TMI 288 - AT - Income TaxReopening of assessment u/s 147 - Reasons to believe - deposits in bank account - information of base sheet received by the Assessing officer that the assessee was having bank account with HSBC, Geneva, Switzerland and assessee was not filing return of income nor disclosed such foreign bank account to the department - CIT(A) confirmed the addition by taking a view that the assessee failed to discharge the onus lies upon him and has not furnished the required evidence and details required by the Assessing officer during the assessment - HELD THAT:- Considering the peculiar facts and circumstances of the case that the assessee has fully disowning his connection with the alleged bank account in HSBC, Geneva, Switzerland and has agreed to sign or undertake on any declaration for seeking further details of the bank account and ready to discharge his onus if all the documents and information in power and possession is provided to the assessee. Therefore, we deem it appropriate to restore the issue back to the file of Assessing Officer. The Assessing Officer is directed to provide all the information and evidence in his power and possession either received or gathered or collected to the assessee. The assessee is also directed to make full cooperation with the Assessing Officer and to file all the information, document or evidence with regard to his Passport, his various visit to foreign countries and the details of Visa (s). The assessee is further directed to give his consent for obtaining further information regarding the base sheet and to sign necessary declaration, undertaking or any other application or declaration as required by the Assessing Officer for obtaining information from foreign countries including impugned bank account with HSBC Bank, Geneva, Switzerland. So far as issue related with the reopening is concerned, we find that the learned Senior Counsel has not made specific submissions, therefore, those issue is treated as not pressed and dismissed as such. However, ground No. (II) is allowed for statistical purpose.
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