Court Dismisses Appeal: No Evidence Linking NRE Account Remittances to Indian Income; Sections 147 and 68 Challenged.

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....Reopening of assessment u/s 147 - Addition u/s 68 - No such evidence to prove the fact that the remittance made by the assessee in his NRE Account or the credit allegedly appearing in HSBC has any source from income in India or routed from any business connection in India. - None of the findings recorded by the CIT(A) have been assailed on the basis of any material or evidence rather based on assumption. Therefore, we do not find any merit in the grounds of appeal raised by the revenue. - AT....