https://www.taxtmi.com/caselaws?id=754127 In a search assessment, additions for AYs 2006-07 and 2007-08 were sustained because the assessee was confronted with complete foreign bank details, accepted the account, did not retract, and revised the returns, so the section 153A challenge failed. Notional interest additions for AYs 2008-09 to 2012-13 were deleted because the only material showed a closed account and there was no evidence to presume continuation or tax hypothetical interest. The treaty-based plea under Article 23(3) of the India-UK DTAA and Notification No. 91/2008 also failed on the facts. Penalties under section 271(1)(c), including the enhancement, were deleted where the underlying additions did not survive or lacked the statutory basis. The alleged fictitious expenditure addition for AY 2010-11 was also deleted for want of independent evidentiary support. en-us Wed, 12 Jun 2024 00:00:00 +0530 Mon, 17 Jun 2024 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754127 In a search assessment, additions for AYs 2006-07 and 2007-08 were sustained because the assessee was confronted with complete foreign bank details, accepted the account, did not retract, and revised the returns, so the section 153A challenge failed. Notional interest additions for AYs 2008-09 to 2012-13 were deleted because the only material showed a closed account and there was no evidence to presume continuation or tax hypothetical interest. The treaty-based plea under Article 23(3) of the India-UK DTAA and Notification No. 91/2008 also failed on the facts. Penalties under section 271(1)(c), including the enhancement, were deleted where the underlying additions did not survive or lacked the statutory basis. The alleged fictitious expenditure addition for AY 2010-11 was also deleted for want of independent evidentiary support. Case-Laws Income Tax Wed, 12 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754127