Non-Resident Assessee Not Liable for Addition on Foreign HSBC Account u/ss 153A and 69A of Income Tax Act.

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....Addition u/s.153A - addition u/s.69A - Assessee was the beneficial owner of the foreign bank account of HSBC Bank at Geneva - Since assessee is a non-resident, at the cost of repetition, there cannot be any addition in respect of a foreign bank account in HSBC Bank, Geneva in India either on substantive or on protective basis. - AT....