2008 (2) TMI 952

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..... A deposit of US S 1,00,000 was found in the bank account of the assessee in Wells Fargo Bank, USA. 3. The matter was referred to the Foreign Tax Division of the CBDT for enquiry and they obtained a report from the American authorities. 4. The report indicates that the amount deposited with the bank came from explained sources. It is also mentioned that the persons who had advanced the sums to ....

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....in an appeal under Section 260A of the Income Tax Act, 1961, it is contended that even though the transaction may be genuine, there is nothing to suggest the creditworthiness of the loanee. We are of the opinion that in view of an inter-Governmental exchange which resulted in a report from the IRS department of the American Government to the Foreign Tax Division of the CBDT, which suggests that th....