https://www.taxtmi.com/caselaws?id=396835 ITAT Mumbai upheld reassessment where the Assessing Officer had prima facie material linking the assessee to a Swiss bank profile and possible escapement of income; the later plea of non-resident status did not invalidate reasons recorded on the basis of the return then available. It also sustained the addition relating to the HSBC Geneva base note, finding documentary material showed beneficial ownership or beneficiary interest in an offshore structure, and applying surrounding circumstances and human probabilities to reject the assessee's explanation. The assessee's refusal to sign the consent waiver supported the inference that fuller foreign-bank verification was frustrated. The appeal was rejected, subject to the existing computation directions. en-us Thu, 16 Jul 2020 00:00:00 +0530 Sat, 11 Oct 2025 12:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396835 ITAT Mumbai upheld reassessment where the Assessing Officer had prima facie material linking the assessee to a Swiss bank profile and possible escapement of income; the later plea of non-resident status did not invalidate reasons recorded on the basis of the return then available. It also sustained the addition relating to the HSBC Geneva base note, finding documentary material showed beneficial ownership or beneficiary interest in an offshore structure, and applying surrounding circumstances and human probabilities to reject the assessee's explanation. The assessee's refusal to sign the consent waiver supported the inference that fuller foreign-bank verification was frustrated. The appeal was rejected, subject to the existing computation directions. Case-Laws Income Tax Thu, 16 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396835