TaxTMI 
TaxTMI 
2025 (5) TMI 502
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....he Revenue : Ms Rajinder Kaur, CIT- DR ORDER PER ANUBHAV SHARMA, JM: These are appeals preferred by both the Revenue as well as the Assessee against the orders of the Ld. First Appellate Authority in appeals filed before him against the orders of the ld. Assessing Officer (hereinafter referred to as the Ld. AO, for short). Further details of the orders of the lower authorities are as under:- ITA No./BMA & Assessment Year CIT(A) who passed the order Appeal No. & Date of order of the CIT(A) AO who passed the assessment order & Date of order Section of the IT Act/BMA under which the AO passed the order ITAs No.405 to 411/Del/2021 AYs: 2011-12 to 2017-18 CIT(A)-24, New Delhi CIT(A), Delhi - 24/10270/2018-19 to CIT(A), Delhi - 24/10273/2018-19, CIT(A), Delhi - 24/10096/2019-20, CIT(A), Delhi - 24/10275/2018-19 & CIT(A), Delhi - 24/10276/2018-19, dated 26.02.2021 ACIT, Central Circle-5, New Delhi, date: 31.12.2018 153A ITAs No. 153/Del/2022, 716/Del/2021 & 165/Del/2022 AYs.2015-16 to 2017-18 - CIT(A), Delhi - 24/10096/2019-20, CIT(A), Delhi - 24/10275/2018-19 & CIT(A), Delhi - 24/10276/2018-19, dated 26.02.2021 ACIT, Central Circle-5, Ne....
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....d by them upto the AY 2015-16 which were completed assessments and for the remaining two AYs i.e 2016-17 and 2017-18, the assessment proceedings were pending and got abated due to the time to issue the notice u/s 143(2) of the Act had not expired as on the date of search. 4. The case of revenue is that as per the information available with the revenue before the date of search on 02/03/2017, Shri Pradeep Wig, Ms. Neera Wig, Ms. Sonu Wig, Ms. Neela Kothari and Ms. Gauri Wig were shareholders of Carmichael Capital Limited (hereinafter referred to as CCL), a British Virgin Island (BVI) registered on 09/03/2005, as per certificate of its incorporation placed at PB page no. 1 Vol. No. 1. The assessee Pradeep Wig and Mrs. Neera Wig, and their 3 daughters including assessee Ms. Sonu Wig, held equal shares of 20% each in CCL. The entire investment was made from the declared and assessed sources remitted from India under the permitted Liberalized Remittance Scheme (LRS) of the Reserve Bank of India from time to time from 04/11/2005 to 31/03/2016. This is an admitted fact by the revenue also as no adverse cognizance of the same in any manner in any of the appellants/assessee has been take....
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....no. 63 at Eaton House from 15/04/2014 for 12 months (Page 18 of the assessment order AY 2011-12) (for the other 2 properties being flat nos. 53 and 61 in the same building, it was NIL but assessed on deemed basis by the AO). It is also an undisputed fact the flat no. 61 belonged to a subsidiary Eaton House of CCL and was never let out. 9. The corresponding details of these transactions are made available on PB and same are not disputed by the Revenue. 10. Thus, as per the appellants/assessee, the said company CCL was not incorporated to acquire the properties as for the almost initial three years the company was only engaged in investment activities of the funds remitted under the permitted LRS from India and which source has been accepted by the revenue as no addition has been made for it. Then as per the case of assessee no dividend was ever declared by those companies to its share holders nor any money otherwise was given to the appellants/ shareholders by the said companies in any manner. 11. Thus, all the above Income-tax appeals and the BMA appeals involve common grounds of appeal, and the first issue for consideration is whether the corporate veil of an overseas BVI....
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....rom the declared tax paid sources. Thus, the assessee acquired shares in a foreign company which were their foreign asset and were duly disclosed in return of income. Ld. Counsel submitted that it is not the concern of assessee as investor, as to what the said company did with the amount received by it from the assessee after allotting shares to the assessee, which shares are the only asset in their hands and the assets of the company, is beyond the scope of this provision. 14. Further, ld. Counsel submits that as per the Explanation 5 u/s 139(1), a beneficiary of an asset can only be an individual who derives benefit from the asset during the previous year, the consideration for which was provided by a person other than such beneficiary. Thus, here the use of word 'and', repeat 'and', in the respective limbs clearly means, the consideration for such asset has to be provided by someone else other than the beneficiary. Since, here the consideration was provided by the assessee only, he could not at all be termed as a beneficiary and on the same analogy, the assessee can also not be considered as a beneficial owner of the asset registered in the name of the company to stretch him ....
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.... there as per evidence placed at PB page no. 279-290 Vol. 1. The said properties were thus exempted in UK from the capital gains tax on their sales. 18. The basic reason to consider the income from the same in the hand of the appellants/assessee is that during the income-tax search conducted on 02/03/2017 on the appellants/assessee, the revenue came across a calendar events date sheet from the mobile phone of Mr Pradeep Wig as is copied in the assessment orders, showing that Mr Pradeep Wig was indulging in maintaining the activities of the properties including using one of the said properties for own residential use in London besides his daughter Ms. Sonu Wig, who is a British citizen, was also living therein. The revenue has contended that the BVI company was incorporated to acquire properties overseas with the sole intention to bypass taxability of income of those London properties in their hands in India. 19. This is rebutted by the Ld. Counsel by reiterating his submission that it is also an admitted fact and as has been mentioned by the AO also that the income-tax department had the information of those properties owned by the overseas companies before the date of search....
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....efore the due date, a return in respect of his income or loss for the previous year in such form and verified in such manner and setting forth such other particulars as may be prescribed:" 20. Now as we go through the impugned orders, it can be appreciated from the impugned order of ld. CIT(A) that aforesaid submissions were not found sustainable for following reasons:- 1.1.4 "I have considered facts of the case as well as written submissions of the appellant. From perusal of the assessment order, it is observed that the Assessing Officer has relied upon following seized material: (i) Seized data titled 'Carmichael Banc Alliance Invoice june 2005.pdf' which is an invoice raised by BANC Alliance to Sh. Pradeep Wig for incorporation of CCL (ii) Calendar events of the appellant from which it is seen that purchase, sale, renovation, leasing, furnishing, loan arrangements, meeting with brokers / estate managers in connection with purchase / sale of flats 53, 63 & 61, Eaton Estate has active involvement of the appellant (iii) Seized documents 'WORKERS [2210] xls', WORKERS [11585] xls', WORKERS [13180] xls', WORKERS.xls' as per which the appellant ha....
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....inimum and such a process constitutes tax evasion. The operative part of the judgment is reproduced below: "23. Tax planning may be legitimate provided it is within the framework of law. Colourable devices cannot be part of tax planning and it is wrong to encourage or entertain the belief that it is honourable to avoid the payment of tax by resorting to dubious methods. It is the obligation of every citizen to pay the taxes honestly without resorting to subterfuges." 4.4.18 The appellant and his family members remitted USD 51,63,720 (Rs 24,74,96,571) to BVI under Liberalised Remittance Scheme from the FY 2004-05 to 31/03/2016. Copy of relevant bank accounts was submitted during appeal proceedings. The appellant made investments in CCL out of above remittance. A comparative balance sheet of CCL from 31.03.2008 to 31.03.2016 is reproduced below: CARMICHAELCAPITAL LTD. PORTCULLIS TRUSTNET CHAMERS. P.O 3444, RED TOWN, TORTOLA COMPARATIVE BALANCE SHEET AS ON31/03/2008 TO 31/03/2016 ASSETS 31/03/2008 31/03/2009 31/03/2010 31/03/2011 31/03/2012 31/03/2013 31/03/2014 31/03/2015 [AMT IN USD $) 31/03/2016 I Tangible Assets....
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.... 29,40,923 NET ASSETS (A-B) 22,16,274 32,61,523 40,82,876 39,01,105 37,00,000 35,86,165 54,67,031 60,96,969 63,70,447 EQUITY AND LIABILITIES 31/03/2008 31/03/2009 31/03/2010 31/03/2011 31/03/2012 31/03/2013 31/03/2014 31/03/2015 31/03/2016 I Shareholders" Funds - Share Capital 3,500 6,000 8,000 8,000 8,000 8,000 8,000 9,100 9,992 a) Ordinary shares of US$ 1 each - Share Premium 17,46,500 29,94,000 39,92,000 39,92,000 39,92,000 39,92,000 39,92,000 45,40,900 49,86,008 a) 499 USD$ per share - Others Reserves a) Share Application Money(Pending Allotment) 3,69,430 28,391 28,391 28,393 28....
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....rue state of affairs. Hon'ble Supreme Court in the case of Mc Dowell & Co. Ltd. Vs. Commercial tax Officer [1985] 154 ITR 148 (SC) held that it is not open to everyone to so arrange his affairs as to reduce burden of taxation to minimum and such a process constitutes tax evasion. The operative part of the judgment is reproduced below: "23. Tax planning may be legitimate provided it is within the framework of law. Colourable devices cannot be part of tax planning and it is wrong to encourage on entertain the belief that it is honourable to avoid the payment of tax by resorting dubious methods. It is the obligation of every citizen to pay the taxes honestly without resorting to subterfuges." 4.4.22 Hon'ble Karnataka High Court in the case of Yenepoya Resins & Chemicals Vs. DCIT [2020] 116 taxmann.com 457 (Karnataka) held that where assessee had deliberately reduced its taxable income through discounting letter of credit against sale bills issued to sister concern instead of collecting proceeds and bore interest burden of sister concern, said arrangement could not be considered as business prudence and deduction claimed by assessee on account of interest paid....
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.... of decision of Hon'ble Supreme Court in the case of Mc Dowell & Co. Ltd. Vs. Commercial tax Officer [1985] 154 IT'R 148 (SC), the Assessing Officer can lift the corporate veil and income of the company can be assessed in the hands of the real owner, the shareholders in this case. It is held that the appellant had invested in properties through CCL and the company has been used as a tool for holding of investment while the real control lies with the appellant. The Assessing Officer has rightly concluded that the properties are owned by the assessee, the company CCL, is a cover and nominee directors have been appointed for the sake of statutory obligations. Hence, income of properties held by CCI. and EEL is liable to be assessed in the hands of Sh. Pradeep Wig and Smt. Neera Wig, who are beneficial owners of these properties. However, the taxability of income from these properties is subject to Indo-UK Double Taxation Avoidance Agreement as well as provisions of Income Tax Act. Relevant provisions of Indo-UK DTAA are reproduced below: "Article 6 INCOME FROM IMMOVABLE PROPERTY 1. Income from immovable property may be taxed in the Contracting State ....
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....enefit of himself or/and someone else. This explicitly refers to a particular asset as the word 'the' has been used to qualify the particular very asset for which the consideration was given by the assessee and not any other asset acquired by the other person to whom some amount was given but not for the asset acquired by the assessee. Thus, we find substance in the contention of ld. Counsel that the ld. Tax authorities have not given any reason to controvert the submissions of the assessee except to make some general observations, based on assumptions and presumptions. There is substance in the contention that ld. Tax authorities have not appreciated the proposition that the shareholders of a company do not at all have any right in the income of the company but their right in the income of the company is only limited to the extent of the dividend or payouts given by the company to its shareholders as per the law. 23. In aforesaid context, the reliance of the ld. Counsel of the appellants/assessee on the decision of the Coordinate Bench, ITAT Jaipur in the case of KrishnaDas Agarwal vs DDIT [2023] 150 taxmann.com 290 (Jaipur- Trib), is quite relevant and seems to be squarely app....
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....directly earned any income. In the search, revenue has not found any material in digital or in a seized material which suggest that there is an income accrued or arise to the assessee in his individual capacity. He also submitted that the comparison in the present case, is that of a non-resident foreign company and not an Indian company. The said vital fact has been accepted and never been disputed by the Ld. AO in the Assessment Order dated 31-3-2021 and/or in the Remand Report dated 13-7-2022. He has further submitted that the Place of Effective Management (POEM) of the said foreign company is also situated outside India because of which, the company is a non-resident in India within the meaning of section 6 of the income tax act and none of the assets were liable to be taxed in India [Reliance was made to the CBDT circular dated 23-2-2017 bearing Circular No. 08/2017]. Based on these clarifications by Board that in no view of the manner can taxability arise in the present case even on POEM and that the entire edifice of the case is wholly unjust and illegal. ...... 38.3 The ld. A/R argued that the concept of a separate legal entity has been a time old principle....
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....r of the company he created. It is quite common in Ireland for one person to have such a variety of roles and still be a different legal entity from the company. LEE v. LEE`S AIR FARMING LTD. (1961) In this case, Mr. Lee formed his crop spraying business into a limited company in which he was director, shareholder and employee. When he was killed in a flying accident, his widow sought social welfare compensation from the State, arguing that Mr. Lee was a workman under the law. The State argued that Mr. Lee was self-employed and thus not covered by the legislation. The court held that Mr. Lee and the company he had formed were separate entities, and it was possible for Mr. Lee to be employed by Lee`s Air Farming. STATE TRADING CORPORATION OF INDIA LTD. AIR (1963) SC 1811 It was held that as soon as citizens form a company, the rights guaranteed to them by article 19(1)c has been exercised and no restraint has been placed on the right and no infringement of that right is made. Once a company or corporation is formed, the business which is carried on by the such company or corporation is the business of that company or corporation and is not the bus....
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....or incorporation of Carmichael Capital Ltd was in the name of the assessee, we are inclined to accept the plea raised by the ld. counsel of the assessee that a company is always got incorporated by its promoter only and same has to pay for the cost of incorporation and therefore, the invoice cannot on its own put a burden of assessee to show what was real intention of incorporation of the company. We find substance, in the plea that it is not the case of the revenue that the consideration for the said invoice was paid from some unknown sources as no addition has been made for the same. Thus this by itself cannot be a reason to lift the corporate veil where intention of tax evasion must be proved. 26. Then we find that the authorities below relied on some calendar events found in the mobile of the assessee as elaborated from page 10 to 13 of the said assessment order which do not show any financial transactions much less not recorded in the books of account. Now where the assessee is an old person above 70 years of age at that time and the share in company are held by his wife and daughters, any such record about the maintenance of the property cannot be a reason to lift the corp....
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....even in case of Tata Engineering & Locomotive Co. Ltd. as also in Life Insurance Corporation V/s. Hari Das Mundhra, reported in 1962 LawSuit (All) 30 as well as in PNB Finance Ltd. V/s. Shital Prasad Jain, reported in 1983 54 Company Cases 66 (Delhi), it has been held by all the Courts consistently that in a given case the Court may lift the corporate veil of a company where it appears that the company was formed only for some fraudulent purpose and to defraud the creditors or to avoid legal obligations. Now in the context of this proposition, if we look at and correlate the clauses contained in Memorandum of Association as well as Articles of Association and correspondingly, to the stand taken by the department, it appears that the company is engaged in altogether other business than the main object for which the company was set up and therefore, in view of settled position of law, if the company has travelled beyond the scope of the object of Memorandum of Association then such transaction has no legal sanctity and can be said to be void and therefore, this improper conduction of business de-hors the main object tantamount to be improper conduct of the company and for that very p....
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....(A) has held calendar information to be 'incriminating material' but devoid of any transactions details, it is not justified to make it basis of piercing the corporate veil on basis of alleged tax evasion by use of a shell company. Rather such arrangements to hold shares in company instead of holding share in property are common due to easy liquidity and even for the purpose of saving stamp duty on transfers or any form of statutory liability. But that in itself cannot be basis to presume arrangement to avoid income tax payable in India. 29. Here itself the nature of Annual Tax on Enveloped Dwellings (ATED), which is an annual charge on UK dwellings held by a Non-Natural Person (NNP) e.g. a company, needs to be examined as the same has many facets effecting this issue. The Annual Tax on Enveloped Dwellings was introduced in UK to tax the ownership of high-value residential property in vehicles that allow the property to be sold free of stamp duty. Effectively, it makes it less attractive for companies to hold high-value UK residential properties. There are some genuine reasons why a 'non-natural person' may own a residential property other than tax avoidance and exemptions do ex....
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....oreign asset and income of a resident person in India. Any amount of foreign asset or income which has not been disclosed in the Income-tax returns in India is subject to imposition of tax and penalties under the BMA w.e.f. AY 2016-17 where this liability arises even in respect of the income and assets pertaining to the earlier periods which were not disclosed earlier and also in the window granted by the Government of India to the resident assessee's to avail the immunity from the penal provisions under the BMA at the time of its implementation in the year 2015. Therefore, the relevant provisions introduced under Act to synchronize applicability of the provisions of the Income-tax Act and the BMA w.e.f. AY 2016-17 needs to be appreciated for adjudication of the issue further. We find that definition of 'beneficial interest' and 'beneficiary' used for assessment of undisclosed foreign income and assets has not been given under the BMA and for the purpose of assessment under the BMA, the same has to be imported from the definition given under the Income-tax Act. The same has been given in the Fourth proviso u/s 139(1) of the Act inserted by the Finance Act, 2015 w.e.f. A.Y. 2016-17 ....
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....uced w.e.f. 01/04/2016 only. 31.4 Now for the purpose of issues the relevant state of law including about the beneficial holding u/s 4 of the BMA are reproduced below; Scope of total undisclosed foreign income and asset. 4. (1) Subject to the provisions of this Act, the total undisclosed foreign income and asset of any previous year of an assessee shall be,- (a) the income from a source located outside India, which has not been disclosed in the return of income furnished within the time specified in Explanation 2 to sub-section (1) or under sub-section (4) or sub-section (5) of section 139 of the Income-tax Act; (b) the income, from a source located outside India, in respect of which a return is required to be furnished under section 139 of the Income-tax Act but no return of income has been furnished within the time specified in Explanation 2 to sub-section (1) or under sub-section (4) or sub-section (5) of section 139 of the said Act; and (c) the value of an undisclosed asset located outside India. (2) Notwithstanding anything contained in sub-section (1), any variation made in the income from a source outside Indi....
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....ssed to tax for any assessment year under this Act, shall be reduced from the value of the undisclosed asset located outside India, if, the assessee furnishes evidence to the satisfaction of the Assessing Officer that the asset has been acquired from the income which has been assessed or is assessable, as the case may be, to tax. (2) The amount of deduction referred to in clause(ii) of sub-section (1) in case of an immovable property shall be amount which bears to the value of the asset as on the first day of financial year in which it comes to the notice of the Assessing Officer, the same proportion as the assessable or assessed foreign income bears to the total cost of the asset. 37. Therefore, what can be concluded is that any income included u/s 5(1) of the BMA shall be reduced from the value of undisclosed asset located outside India if the said assets have been acquired from the income which has been assessed or is assessable as the case may be to tax in India under the Income-tax Act 1961. Thus, for the purpose of excluding such asset from the rigors of the BMA is that the assessee proves the source of acquisition the foreign asset from a tax paid money.....
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....ed sources money through the permitted LRS form India since the year 2005 till 2016, as has been admitted by the AO also as for which no addition has been made under the Income-tax Act as well as the BMA. It is also undisputed legal position that the share capital of any company is its own money and which was used by the UK company to acquire properties there in its own name. It is also a settled legal position that the amounts received in its share capital by a company is irreversible during the existence of the company, and it remains its own money. The shareholder loses all his right over the money invested in the share capital of the company and also on all the assets which the company acquires by using the said share capital amount. The shareholder of the company is only entitled to receive dividends as and when the company declares or on the winding up of the company to the residual value as may be portioned to the shareholder by the liquidator. In both the situations, the shareholders do not have any right over the assets of the company in any manner whether direct or beneficial. Ownership of the shares in and ownership of the assets of the company are two different connotat....
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.... also placed at PB page no. 238 which categorically stated "To clarify your below request; the Authorised Signatories have completed the online banking for PW and SW to have view access only." 41. Then the ld. Counsel for the assessee submits that even otherwise the income from the said properties could not be assessed at all in India because of the Article 6 of the DTAA with the UK and same is mentioned in para 6 on the page no. 15 of the assessment order and para 4.4.23 on the page 78 of the CIT(A)'s order and reproduced here in below: "1. Income from immovable property may be taxed in the Contracting State in which such property is situated." 42. Thus, on a plain reading of the above, it is clear the said clause is not at all a person based but is only the property based. No interpretation of the same vis a vis the person (assessee) can be drawn by relying on the said Article as such. It only refers to the income from a property where to be assessed, not in whose hands. However, the revenue has considered the word used "may" be assessed in the said DTAA as may be assessed in the country of residence other than the country where the property held as against the spe....
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....sons to whom deemed rental income can be attributed and by piercing corporate veil deeming ownership could not have been alleged. A deeming income provision needs strict application and by way of adverse presumption or principle of piercing of veil the property of company cannot be held to be lying with the share holders or directors, so as to add income in their hands. If the registered owner does not exploit its property, then it is its choice and not of the beneficial owner. In this context reliance can be placed on the following decisions:- (i) R B JodhamalKuthiala vs CIT (1971) 82 ITR 587 (SC) (ii) CIT vs Poddar Cement (P) Ltd (1997) 226 ITR 625 (SC) (iii) New Cotton and Wool Pressing Factory 65 ITR 662 (Raj) 45. It can be further seen that the entire information about the investment in the overseas companies holding of properties by the overseas company in UK, purchased from its own capital received from the assessee and his family and bank loan borrowed from the HSBC Bank in UK and other relevant factors were well-known to the Revenue much before the date of search on 02/03/2017 as the statements u/s 131(1A) of the Act of the assessee and his fa....
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....lutely absent rather not concealed of. 47. Then we find that the 3 daughters of the assessee were majors and those shares were registered in their own names only with no beneficial interest of anyone else. No evidence has been brought on record by the AO that the daughters ever tried to exit from their respective interest in their shareholdings in favour of the assessee. It is also seen that Ms. Sonu Wig, one of the daughters of the assessee was an NRI rather became British citizen, holding a British passport since the year 2013 and was residing in the said property overseas off and on. That only shows natural course of events and nothing incriminating. 48. We are thus inclined to hold that the assessee/appellants were not the beneficial owner of any property or asset of CCL and therefore neither any income arising from the property of the said company as rent nor as capital gains and also the bank interest nor any other income of the company form any source, was assessable in the hands of the assessee or any family member who had never had any beneficial ownership or holding any beneficial interest in the assets of the company. Thus, the action of the both the authorities in....
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....e provisions of section 51 of the Act and could not be treated as 'income from other sources' in this year of receipt of advance in the absence of any such provision under the Act. Thus, the addition so made should be deleted." 50. In respect of the addition of Rs 43,90,240/- made in the AY 2012-13 in the hands of Ms. Neera Wig by the AO claiming that the assessee failed to prove the refund of the advance of Rs 45,00,000/- received besides not able to identify the prospective buyer of the property of Plot No. BD-5, Sector-B, part of Khasra no. 88/3 in the residential colony known as Greenfields at Faridabad (Haryana) and then making an addition u/s 51 of the Act we reproduce the relevant provision below:- "Section 51 of the Act provides that - Where any capital asset was on any previous occasion the subject of negotiations for its transfer, any advance or other money received and retained by the assessee in respect of such negotiations shall be deducted from the cost for which the asset was acquired or the written down value or the fair market value, as the case may be, in computing the cost of acquisition." 51. The assessee submitted before the lower author....
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....nd sale consideration be taken as circle rate. The assessee in her response submitted that market value of the property was lesser than circle rate in view of location of the property. However, no documentary evidence was submitted in support of her contention. Hence, reply of the assessee is not acceptable and the full value of consideration of the property is taken as Rs. 90,00,000/- in terms of section 50C of the Act. Since cost of acquisition has already been reduced nil against advance received during AY 2012-13, sale consideration received of Rs. 45 lacs is taxable as capital gain. The assessee has already offered capital gain of Rs. 36,98,490/- on this transaction, difference amount of Rs. 8,01,510/- is brought to tax as capital gain." 54. The Ld. Counsel stated that once the appellants/assessee raised an objection to the same, the AO was duly legally obliged to refer the same to the DVO u/s 50C(2)(a) of the Act to determine the FMV as on the date of the sale and could not take any call himself to determine the FMV being the stamp duty valuation in violation to the provisions of the section. Moreover, the advance received by the assessee was just Rs 22,50,000/- 5....
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.... incomes sourced from the BVI company are allowed by deleting all those additions and the appeals of the department on those issues are dismissed. 59. Similarly, in respect of the grounds raised by the department challenging the deletion of the addition of USD 50,000 in the hands of Mr Pradeep Wig in respect of the amount remitted by his late mother from the declared sources, and inherited by the assessee, the department did not make any new submissions even to contradict the findings of the CIT(A). The assessee relied on the order of the CIT(A) in this regard. Thus, the detailed reasoned order on the issue of the CIT(A), is sustained.. 60. In respect of the addition of bank interest assessed as received from the Citi Bank Singapore, the CIT(A) has held as below by the common findings in respect of assessability of the interest earned in a jointly held but already closed Citi Bank account in Singapore:- "5.38 Further, vide ground no. 15, the assessee submitted that the Citi Bank, Singapore account for which an addition of Rs 4,31,653/- has been made in the hands of the assessee was in the name of five persons namely: Mr. Pradeep Wig, Ms. Neera Wig, Ms. Neela Kothari,....