ACIT CENTRAL CIRCLE 8(2) MUMBAI, MUMBAI vs. MUKESH D AMBANI, MUMBAI

ITA 5118/MUM/2024Status: DisposedITAT Mumbai31 January 2025AY 2005-0634 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(A) was justified in deleting the additions. The AO's reliance on a 'Base Note' for the existence of a second account was found insufficient, as the note primarily detailed one account and the BUP ID in question was identified as a client profile code, not a separate account number.

What were the facts?

The Revenue appealed against the deletion of additions made on account of alleged undisclosed foreign bank accounts and interest income. The Assessing Officer (AO) reopened the assessment based on information suggesting the assessee held foreign bank accounts with HSBC, Geneva, which were not disclosed in the return of income.

What were the issues?

Whether the AO was justified in making additions for undisclosed foreign bank accounts and interest income based on available information, and whether the BUP IDs constituted account numbers.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 149

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH MUMBAI

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

Hearing: 21.01.2025Pronounced: 31.01.2025

PER BENCH: These six appeals filed by the Revenue and corresponding six Cross Objections filed by the assessee are against the order of Ld. CIT(A)-50, Mumbai, dated 02.08.2024 passed against the assessment order of DCIT-3(3)(1)/DCIT-Central Circle – 8(2), Mumbai, u/s.143(3)

The order continues below.

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