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ITAT allowed the assessee's appeal regarding additions made during search proceedings. The Tribunal deleted the notional interest addition on HSBC Geneva account, finding the account had NIL balance with maintenance charges rather than interest income, following precedent in Krishan Kumar Modi case. Cash addition of INR 2,78,142 was deleted as the assessee satisfactorily explained the source through bank withdrawals made within thirty days before search. Jewellery addition of INR 1,01,52,902 was deleted since total explained jewellery (3,785.25 grams) exceeded seized jewellery (3,619.170 grams) through VDIS declarations, gifts, purchases, and CBDT exemption limits. The assessment was held not time-barred due to valid extension under section 158B. Penalty under section 271(1)(c) was deleted following deletion of substantive additions, as no concealment of income particulars remained.
ITAT allowed the assessee's appeal regarding additions made during search proceedings. The Tribunal deleted the notional interest addition on HSBC Geneva account, finding the account had NIL balance with maintenance charges rather than interest income, following precedent in Krishan Kumar Modi case. Cash addition of INR 2,78,142 was deleted as the assessee satisfactorily explained the source through bank withdrawals made within thirty days before search. Jewellery addition of INR 1,01,52,902 was deleted since total explained jewellery (3,785.25 grams) exceeded seized jewellery (3,619.170 grams) through VDIS declarations, gifts, purchases, and CBDT exemption limits. The assessment was held not time-barred due to valid extension under section 158B. Penalty under section 271(1)(c) was deleted following deletion of substantive additions, as no concealment of income particulars remained.
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