Corroboration for foreign tax information is essential; additions failed where ownership of alleged overseas deposits was not proved.

Additions based on foreign information and alleged statements could not be sustained where the Revenue failed to conduct timely inquiry or obtain corroborative material establishing that the foreign deposits belonged to the deceased assessee. The reopening rested largely on UK-sourced material, but no meaningful investigation was made from available sources, and the delay in acting on the information further weakened the case. In the absence of evidence linking the foreign funds to the assessee, the material was insufficient to justify the assessment additions, which were therefore not restored.

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Issues: Whether the additions made on the basis of information received from the UK authorities and the assessee's alleged statements could be sustained in the absence of corroborative material and timely investigation.

Analysis: The reopening was triggered by information received under the Indo-UK tax arrangement, but the Revenue did not act with promptness and waited for years before reopening an old assessment after the assessee had died. No meaningful enquiry was made from available sources that could have confirmed the source or ownership of the alleged foreign deposits, and the case rested almost entirely on the UK material. The absence of corroborative evidence and the failure to develop available leads meant that the material was insufficient to establish that the foreign funds belonged to the deceased assessee.

Conclusion: The additions could not be sustained and the finding was in favour of the assessee.

Final Conclusion: The question of law was answered against the Revenue, and the assessment additions were not restored.

Ratio Decidendi: A tax addition based primarily on foreign information and alleged statements cannot stand without timely inquiry and corroborative material establishing ownership of the income.

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