Foreign bank account balance taxed again was deleted where the same deposit had already been considered in a later year.

Addition based on an overseas bank account balance under section 69A was deleted because the same deposit had already been brought to tax in a later year on the same facts and information. The appellate authority held that the initial deposit could not be separated from the carried-forward balance for a fresh addition, as that would amount to double taxation. In the absence of any further material showing undisclosed income beyond the information already considered, no additional addition was justified. The deletion of the addition was therefore upheld.

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Issues: Whether the addition made on account of the balance in the foreign bank account was liable to be sustained under section 69A of the Income-tax Act, 1961.

Analysis: The addition was founded on information regarding an overseas bank account and on the inference that the balance represented undisclosed income. The appellate authority found that the amount initially treated as taxable deposit had already been taken into account in the later assessment year on the same set of facts and information. It held that the initial deposit could not be isolated from the subsequent carried-forward balance, and that making a further addition on the same material would result in double taxation. No further material was brought on record to justify any addition beyond what was already reflected in the information available.

Conclusion: The deletion of the addition was upheld and the revenue's challenge failed.

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