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    <title>2023 (4) TMI 742 - ITAT DELHI</title>
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    <description>Exchange-of-information material, without independent corroboration, was held insufficient to prove undisclosed foreign bank income. In completed assessments under section 153A, additions had to rest on incriminating material found during search, and a statement under section 132(4) alone could not sustain additions absent supporting search evidence. The connected additions for children&#039;s bank deposits, alleged cash purchase of air conditioners, reimbursement on flat sale, and notional interest were also deleted because the factual basis was not established or the underlying foreign account addition failed. Penalties dependent on those additions likewise could not survive once the substantive additions were set aside.</description>
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      <title>2023 (4) TMI 742 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=436716</link>
      <description>Exchange-of-information material, without independent corroboration, was held insufficient to prove undisclosed foreign bank income. In completed assessments under section 153A, additions had to rest on incriminating material found during search, and a statement under section 132(4) alone could not sustain additions absent supporting search evidence. The connected additions for children&#039;s bank deposits, alleged cash purchase of air conditioners, reimbursement on flat sale, and notional interest were also deleted because the factual basis was not established or the underlying foreign account addition failed. Penalties dependent on those additions likewise could not survive once the substantive additions were set aside.</description>
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