TaxTMI 
TaxTMI 
2024 (9) TMI 193
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....passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 30.09.2016 by the Assessing Officer, ACIT, Central Circle-07, New Delhi (hereinafter referred to as 'ld. AO'). 2. The assessee has raised the following grounds of appeal :- "1. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making addition of Rs. 53,92,649/- on account of notional interest on the alleged bank account with HSBC and that too by recording incorrect facts and findings and in violation of principles of natural justice and without confronting the entire adverse material available on records. 2. That in any case and in any view of the matter,....
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....neva. The ld AO relied on the observation made by his processor for AY 2006-07 assessment orders framed in the case of the assessee. The assessee in response to the query raised by the ld AO submitted that no bank account with HSBC Bank, Geneva was maintained by him and accordingly there is no interest income thereon. The ld AO however did not heed to this contention of the assessee. Similar explanation given by the assessee in earlier years were rejected by the ld AO wherein, interest income @4% on the alleged deposit balance was added year on year. The ld AO during the year under consideration made the same addition of notional interest @4% on the deposit balance. The deposit balance was added in FY 2006-07 and thereafter interest @4% alo....
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....sequential interest income were deleted. The ld AR submitted that since the ld CIT(A) had placed reliance on the order passed by his predecessor for the same assessment years, when these orders are quashed by Tribunal, no addition towards interest income could be made for the year under consideration in the case of the assessee. 6. Per contra, the ld DR vehemently submitted that the assessee did not furnish any information despite material seized from the residence at the time of search. He vehemently placed reliance on the decision of the Mumbai Tribunal in the case of Renu T. Tharani in ITA No. 2333/Mum/2018 for AY 2006-07 dated 16.07.2020, wherein, the initial deposit was made in the foreign bank account by some trust where Renu T Thara....
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....ase for AY 2006-07 to 2011-12 vide order dated 01.06.2021 referred (supra) had held as under:- "8. We have considered the rival submissions and perused the material on record. It is not in dispute that search was conducted in the case of assessee on 28.07.2011. Both the parties have placed on record copies of the panchanama in the case of assessee at the time of search and thereafter, but, the same did not disclose if any, incriminating material much less than the material was found during the course of search to connect the assessee with maintenance of any bank account with HSBC, Geneva, Switzerland. The Ld. D.R. also placed on record letter of the A.O. Dated 22.08.2019 in which it is clearly mentioned by the A.O. that last panchanama wa....