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The ITAT ruled that additions made by the AO based solely on credits in the non-resident assessee's NRE accounts were unsustainable without establishing that the original source of funds was taxable in India. Following precedents in Nitin Mavji Vekariya and Bhavesh Chandrakantbhai Bhatt, the Tribunal held that NRE deposits from foreign remittances are exempt under s.10(4). For AY 2013-14, the HSBC Bank (NRE) addition was deleted as it represented redemption of an NRE fixed deposit, while HDFC and Deutsche Bank additions were remanded for verification of source. For AY 2015-16, the HDFC Bank (NRE) addition was deleted as it constituted an inward remittance from JP Morgan Chase Bank, UK. The appeal was partly allowed with directions for further verification.
The ITAT ruled that additions made by the AO based solely on credits in the non-resident assessee's NRE accounts were unsustainable without establishing that the original source of funds was taxable in India. Following precedents in Nitin Mavji Vekariya and Bhavesh Chandrakantbhai Bhatt, the Tribunal held that NRE deposits from foreign remittances are exempt under s.10(4). For AY 2013-14, the HSBC Bank (NRE) addition was deleted as it represented redemption of an NRE fixed deposit, while HDFC and Deutsche Bank additions were remanded for verification of source. For AY 2015-16, the HDFC Bank (NRE) addition was deleted as it constituted an inward remittance from JP Morgan Chase Bank, UK. The appeal was partly allowed with directions for further verification.
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