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ITAT held that the assessing officer's treatment of a BUP identifier as a separate undisclosed foreign bank account was unsustainable and quashed substantive additions based on the presumption that the assessee maintained an undisclosed HSBC Geneva account; the record showed the BUP ID was a name identifier linked to an already-assessed profile whose peak balance had been taxed in the earlier assessment year, and the AO failed to controvert the assessee's supporting material. Protective and substantive additions founded on that premise were disallowed. Further, reopening of assessments for A.Y. 2001-02 to A.Y. 2005-06 was held invalid as barred by limitation and thus the reassessment proceedings for those years were set aside.
ITAT held that the assessing officer's treatment of a BUP identifier as a separate undisclosed foreign bank account was unsustainable and quashed substantive additions based on the presumption that the assessee maintained an undisclosed HSBC Geneva account; the record showed the BUP ID was a name identifier linked to an already-assessed profile whose peak balance had been taxed in the earlier assessment year, and the AO failed to controvert the assessee's supporting material. Protective and substantive additions founded on that premise were disallowed. Further, reopening of assessments for A.Y. 2001-02 to A.Y. 2005-06 was held invalid as barred by limitation and thus the reassessment proceedings for those years were set aside.
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