https://www.taxtmi.com/caselaws?id=758808 The ITAT Ahmedabad dismissed the assessee's challenges to reassessment orders under Section 147 for undisclosed foreign bank accounts. The Tribunal held that reopening was valid as foreign assets trigger deemed escapement under Section 147 Explanation 2(d), rejecting claims of borrowed satisfaction and insufficient opportunity. The AO's jurisdiction under Section 153A was upheld based on incriminating material found during search, including statements recorded under Section 132(4). Credit entries in foreign accounts were correctly treated as income under Sections 68/69A, with the CIT(A) appropriately allowing expense deductions. The Tribunal confirmed additions for unexplained jewellery and dismissed claims for loss carry-forward due to non-filing of returns within prescribed time limits. en-us Tue, 10 Sep 2024 00:00:00 +0530 Mon, 16 Sep 2024 17:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758808 The ITAT Ahmedabad dismissed the assessee's challenges to reassessment orders under Section 147 for undisclosed foreign bank accounts. The Tribunal held that reopening was valid as foreign assets trigger deemed escapement under Section 147 Explanation 2(d), rejecting claims of borrowed satisfaction and insufficient opportunity. The AO's jurisdiction under Section 153A was upheld based on incriminating material found during search, including statements recorded under Section 132(4). Credit entries in foreign accounts were correctly treated as income under Sections 68/69A, with the CIT(A) appropriately allowing expense deductions. The Tribunal confirmed additions for unexplained jewellery and dismissed claims for loss carry-forward due to non-filing of returns within prescribed time limits. Case-Laws Income Tax Tue, 10 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758808