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Validity of reopening assessment u/s 147 regarding undisclosed foreign bank account income examined. Non-providing sufficient opportunities and violation of principles of natural justice dismissed as assessee denied ownership initially but later failed to substantiate. Reopening justified under Explanation 2(d) to section 147 deeming foreign asset income as escaped assessment, not based on borrowed satisfaction. Reasons specific, not vague or scanty, quantification not required u/s 149(1)(c) for foreign assets. Reopening within 16-year limitation period upheld. Incriminating materials like statements u/s 132(4) and documentary evidence established ownership of foreign accounts by assessee. Deposits of cheques in assessee's name in accounts proved ownership. Applicability of sections 68/69A on unexplained credits upheld as bank ledgers akin to books of accounts. Losses denied for non-filing returns within due dates u/s 139(1). Remand on quantification of profits/losses from transactions. Deletion of protective jewelry addition in wife's hands after declaration under Vivad se Vishwas Scheme. Substantive unexplained jewelry addition in assessee's hands confirmed based on holistic view by CIT(A). Protective addition in deceased husband's hands rendered infructuous, entire addition treated substantive in wife's hands as legal heir.
Validity of reopening assessment u/s 147 regarding undisclosed foreign bank account income examined. Non-providing sufficient opportunities and violation of principles of natural justice dismissed as assessee denied ownership initially but later failed to substantiate. Reopening justified under Explanation 2(d) to section 147 deeming foreign asset income as escaped assessment, not based on borrowed satisfaction. Reasons specific, not vague or scanty, quantification not required u/s 149(1)(c) for foreign assets. Reopening within 16-year limitation period upheld. Incriminating materials like statements u/s 132(4) and documentary evidence established ownership of foreign accounts by assessee. Deposits of cheques in assessee's name in accounts proved ownership. Applicability of sections 68/69A on unexplained credits upheld as bank ledgers akin to books of accounts. Losses denied for non-filing returns within due dates u/s 139(1). Remand on quantification of profits/losses from transactions. Deletion of protective jewelry addition in wife's hands after declaration under Vivad se Vishwas Scheme. Substantive unexplained jewelry addition in assessee's hands confirmed based on holistic view by CIT(A). Protective addition in deceased husband's hands rendered infructuous, entire addition treated substantive in wife's hands as legal heir.
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