Foreign remittance under section 68 requires full factual verification before any addition, leading to remand for fresh adjudication.

Foreign remittance received from Singapore required factual verification before any addition under section 68 could stand. The assessee had produced the investment agreement, foreign inward remittance certificate, bank records and RBI permissions to support the receipt as investment, but the appellate enhancement was made without proper examination of that material. As the source of funds and the applicability of section 68 depended on a full transaction-level inquiry, the matter was set aside and remitted to the Assessing Officer for fresh adjudication.

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Issues: Whether the enhancement made by the Commissioner of Income Tax (Appeals) on account of the foreign remittance received from Singapore required interference and whether the matter should be restored for fresh examination under section 68.

Analysis: The assessee had placed on record the investment agreement, foreign inward remittance certificate, bank-related materials and RBI permissions to support the receipt of funds as investment. The appellate authority had enhanced the income without a proper examination of the supporting material. Since the source of the remittance and the applicability of section 68 required a factual verification of the entire transaction, the issue was found fit for de novo consideration by the Assessing Officer.

Conclusion: The matter was set aside and remitted to the Assessing Officer for fresh adjudication of the foreign remittance issue under section 68.

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