https://www.taxtmi.com/caselaws?id=362347 Reassessment was upheld because the Base Note and allied material provided a rational basis to believe that income had escaped assessment, satisfying the threshold for reopening under sections 147 and 148. The peak-credit addition in the HSBC Geneva account was deleted because the assessee was a non-resident, so only income received, deemed received, accrued, or deemed to accrue in India was taxable under sections 5(2) and 9; the Revenue did not establish that the foreign deposits had an Indian source, and the circumstantial material was inconclusive. The same income had also been assessed in related hands, further undermining the addition. en-us Tue, 19 Jun 2018 00:00:00 +0530 Sat, 23 Jun 2018 08:34:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362347 Reassessment was upheld because the Base Note and allied material provided a rational basis to believe that income had escaped assessment, satisfying the threshold for reopening under sections 147 and 148. The peak-credit addition in the HSBC Geneva account was deleted because the assessee was a non-resident, so only income received, deemed received, accrued, or deemed to accrue in India was taxable under sections 5(2) and 9; the Revenue did not establish that the foreign deposits had an Indian source, and the circumstantial material was inconclusive. The same income had also been assessed in related hands, further undermining the addition. Case-Laws Income Tax Tue, 19 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362347