https://www.taxtmi.com/caselaws?id=760668 In a concluded search assessment under section 153A, a prior finding that the material constituted incriminating evidence could not be reopened, so the jurisdictional objection failed. On merits, the addition relating to the alleged HSBC Switzerland account was sustained because the record linked the assessee to the foreign account and the refusal to sign the consent waiver was treated as adverse; the absence of a further verificatory report did not displace the existing material. However, once the account was shown to have been closed in 2006, the basis for notional interest disappeared, and the consequential penalty founded on that interest also failed. en-us Fri, 30 Aug 2024 00:00:00 +0530 Thu, 24 Oct 2024 16:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760668 In a concluded search assessment under section 153A, a prior finding that the material constituted incriminating evidence could not be reopened, so the jurisdictional objection failed. On merits, the addition relating to the alleged HSBC Switzerland account was sustained because the record linked the assessee to the foreign account and the refusal to sign the consent waiver was treated as adverse; the absence of a further verificatory report did not displace the existing material. However, once the account was shown to have been closed in 2006, the basis for notional interest disappeared, and the consequential penalty founded on that interest also failed. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760668