TMI Blog2021 (3) TMI 1297X X X X Extracts X X X X X X X X Extracts X X X X ..... hat A.O. was not having any information/material so as to prove that assessee maintained the same HSBC account for the assessment year under appeal. A.O. in the absence of bank statement and further details presumed that assessee must have earned interest on the same foreign bank account in assessment year under appeal. It was, therefore, clearly support the findings of fact recorded by the Ld. CIT(A) that there were no evidence available with the A.O. to compute the interest earned by the assessee in assessment year under appeal. In the absence of any evidence on record to the effect that assessee maintained any foreign bank account in assessment year under appeal or earned any interest thereon, the Ld. CIT(A) was justified in deleting ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The addition has been made by the A.O. considering that there must have been a component of interest earned on the said deposit and he has taken 4% interest which is interest rate generally given by the Banks. 4.1. The Ld. CIT(A) considering the explanation of assessee, deleted the addition. The findings of the Ld. CIT(A) in para 15.1 of the impugned order is reproduced as under: 15.1. It has been observed that the addition has been made on the basis of presumption that the deposit found in the bank account is provided with the interest @ 4%. As per the document, based on which it is found that the appellant has made unexplained deposits in the said bank accounts of HSBC Bank at Geneva, Switzerland, has no mention about such interes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ounsel for the Assessee submitted that addition is made merely on presumption, therefore, it was rightly deleted by the Ld. CIT(A). In view of the above submissions, it is clear that there were no basis for the A.O. to make any addition of interest on such bank account maintained by the assessee with HSBC Bank at Geneva, Switzerland. The A.O. in the assessment order has specifically mentioned that the bank statement available with the Department contains the peak balance maintained in the bank account of assessee with HSBC Bank at Geneva, Switzerland from November, 2005 to February, 2007. The details of the same are also noted in para-10 of the assessment order. The A.O. further noted that as per the information available with the Departmen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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