https://www.taxtmi.com/caselaws?id=754127 ITAT Delhi upheld search assessment u/s 153A despite no incriminating material found during search, as assessee accepted HSBC London bank account documents and filed revised returns. Tribunal rejected electronic evidence objections under s.65B Indian Evidence Act since assessee accepted documents without retraction. Indo-UK DTAA Article 23(3) relief denied as assessee failed to establish source of deposits or prove income earned outside India. Notional interest additions for AY 2008-09 to 2012-13 deleted as AO lacked evidence of account existence beyond statement period. Penalties u/s 271(1)(c) deleted for all years as no material found during search and no concealment established. Revenue's appeal on loose sheet additions dismissed. 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 ITAT Delhi upheld search assessment u/s 153A despite no incriminating material found during search, as assessee accepted HSBC London bank account documents and filed revised returns. Tribunal rejected electronic evidence objections under s.65B Indian Evidence Act since assessee accepted documents without retraction. Indo-UK DTAA Article 23(3) relief denied as assessee failed to establish source of deposits or prove income earned outside India. Notional interest additions for AY 2008-09 to 2012-13 deleted as AO lacked evidence of account existence beyond statement period. Penalties u/s 271(1)(c) deleted for all years as no material found during search and no concealment established. Revenue's appeal on loose sheet additions dismissed. Case-Laws Income Tax Wed, 12 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754127