https://www.taxtmi.com/caselaws?id=432268 An alleged unexplained credit under section 68 was not finally sustained on the existing record because the source, creditworthiness, genuineness of the foreign remittance, and its purpose were not satisfactorily established. As additional material had been sought under rule 29 and further bank statements and supporting documents could still be produced, the matter was restored to the CIT(A) for de novo adjudication after granting the assessee an additional opportunity. The levy of interest under section 234B was also sent back for reconsideration, with liberty to raise the Indo-Portugal treaty non-discrimination clause under Article 24(1) before the first appellate authority if pressed again. en-us Mon, 31 Oct 2022 00:00:00 +0530 Sat, 31 Dec 2022 14:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432268 An alleged unexplained credit under section 68 was not finally sustained on the existing record because the source, creditworthiness, genuineness of the foreign remittance, and its purpose were not satisfactorily established. As additional material had been sought under rule 29 and further bank statements and supporting documents could still be produced, the matter was restored to the CIT(A) for de novo adjudication after granting the assessee an additional opportunity. The levy of interest under section 234B was also sent back for reconsideration, with liberty to raise the Indo-Portugal treaty non-discrimination clause under Article 24(1) before the first appellate authority if pressed again. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432268