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    <title>Assessment additions based on BUP identifier as separate undisclosed foreign account quashed; reassessments for AYs barred by limitation</title>
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    <description>ITAT held that the assessing officer&#039;s treatment of a BUP identifier as a separate undisclosed foreign bank account was unsustainable and quashed substantive additions based on the presumption that the assessee maintained an undisclosed HSBC Geneva account; the record showed the BUP ID was a name identifier linked to an already-assessed profile whose peak balance had been taxed in the earlier assessment year, and the AO failed to controvert the assessee&#039;s supporting material. Protective and substantive additions founded on that premise were disallowed. Further, reopening of assessments for A.Y. 2001-02 to A.Y. 2005-06 was held invalid as barred by limitation and thus the reassessment proceedings for those years were set aside.</description>
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    <pubDate>Mon, 01 Sep 2025 08:13:51 +0530</pubDate>
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      <title>Assessment additions based on BUP identifier as separate undisclosed foreign account quashed; reassessments for AYs barred by limitation</title>
      <link>https://www.taxtmi.com/highlights?id=92087</link>
      <description>ITAT held that the assessing officer&#039;s treatment of a BUP identifier as a separate undisclosed foreign bank account was unsustainable and quashed substantive additions based on the presumption that the assessee maintained an undisclosed HSBC Geneva account; the record showed the BUP ID was a name identifier linked to an already-assessed profile whose peak balance had been taxed in the earlier assessment year, and the AO failed to controvert the assessee&#039;s supporting material. Protective and substantive additions founded on that premise were disallowed. Further, reopening of assessments for A.Y. 2001-02 to A.Y. 2005-06 was held invalid as barred by limitation and thus the reassessment proceedings for those years were set aside.</description>
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      <pubDate>Mon, 01 Sep 2025 08:13:51 +0530</pubDate>
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