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    <title>2026 (7) TMI 1384 - ITAT MUMBAI</title>
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    <description>Foreign investments and bank balances cannot be treated as undisclosed assets where the taxpayer substantiates their foreign source through notarised gift declarations, banking records and verified donor confirmations. The article states that, after independent verification found no material discrediting the donors, transactions or source, and no evidence showed income undisclosed or taxable in India, suspicion could not replace proof; the addition was therefore deleted. As the penalty rested entirely on that addition, it had no independent basis and was also deleted. The stated principle is that verified source evidence, unrebutted by the Revenue, defeats classification of foreign assets as undisclosed.</description>
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      <title>2026 (7) TMI 1384 - ITAT MUMBAI</title>
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      <description>Foreign investments and bank balances cannot be treated as undisclosed assets where the taxpayer substantiates their foreign source through notarised gift declarations, banking records and verified donor confirmations. The article states that, after independent verification found no material discrediting the donors, transactions or source, and no evidence showed income undisclosed or taxable in India, suspicion could not replace proof; the addition was therefore deleted. As the penalty rested entirely on that addition, it had no independent basis and was also deleted. The stated principle is that verified source evidence, unrebutted by the Revenue, defeats classification of foreign assets as undisclosed.</description>
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