Court Rules Presumption Insufficient Without Concrete Evidence in HSBC Bank Account Case Under DTAA Provisions.

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....Addition based on foreign HSBC bank accounts - information received from French Government under DTAA - no material or evidence to say that the assessee was connected with the bank accounts in question - addition is is based on the presumption that the assessee has routed the money sourced from India through the three entities into the bank accounts in question - presumption, howsoever, strong cannot substitute an evidence - no addition....