https://www.taxtmi.com/caselaws?id=449677 ITAT Chennai allowed the appeal challenging additions under Section 10(3) of Black Money Act, 2015 regarding undisclosed foreign assets in Windsor Trust and Dalham Trust. The assessee, though settlor and first beneficiary, proved all contributions were made by his son, a US citizen. The AO relied solely on CRS information without corroborative evidence like bank statements or proof of outward remittances. The Tribunal found the assessee neither contributed funds nor received benefits from the trusts. Enforcement Directorate confirmed investments were explained through bank loans. CIT(A) erred in sustaining additions without proper evidence. The Tribunal held that being a settlor doesn't automatically make one a beneficial owner requiring disclosure in ITR when no actual investment or income exists. en-us Wed, 07 Feb 2024 00:00:00 +0530 Tue, 27 Aug 2024 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449677 ITAT Chennai allowed the appeal challenging additions under Section 10(3) of Black Money Act, 2015 regarding undisclosed foreign assets in Windsor Trust and Dalham Trust. The assessee, though settlor and first beneficiary, proved all contributions were made by his son, a US citizen. The AO relied solely on CRS information without corroborative evidence like bank statements or proof of outward remittances. The Tribunal found the assessee neither contributed funds nor received benefits from the trusts. Enforcement Directorate confirmed investments were explained through bank loans. CIT(A) erred in sustaining additions without proper evidence. The Tribunal held that being a settlor doesn't automatically make one a beneficial owner requiring disclosure in ITR when no actual investment or income exists. Case-Laws Income Tax Wed, 07 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449677