Section 153(5) applies where effect can be given without making...

Section 153(5) applies where effect can be given without making a fresh assessment or reassessment. Where a Tribunal remand requires the Assessing Officer to undertake fresh consideration, the limitation period for fresh assessment under section 153(3) applies; the proviso to section 153(5) also covers matters requiring verification or an opportunity of hearing. Foreign currency may be treated as unexplained money where the taxpayer provides inconsistent explanations and fails to prove its source through satisfactory evidence, including acquisition from authorised dealers. FEMA confiscation for excess possession does not by itself establish the currency's source for income-tax purposes. The addition as deemed income and the associated tax treatment were sustained.