TaxTMI 
TaxTMI 
2025 (1) TMI 1691
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....um/2024 for Assessment Year 2001-02 and Cross Objection No. 233/Mum/2024 as lead case and its finding will be applied mutatis mutandis to the other appeals and cross objections, as applicable. ITA No. 5141/Mum/2024 2. Grounds taken by the Revenue are reproduced as under: "1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the substantive and protective addition made on account of deposits made by the assessee and on account of interest received by the assessee in the foreign bank account in HSBC Bank Geneva, by disregarding the fact that the assessee had opened foreign bank accounts and had not disclosed the same in his Return of Income?" "2. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in not considering the BUP IDs as account numbers, by disregarding the fact that the same information received in the base note received from the Government of France under Indo France DTAA?" "3. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the substantive and protective addition made on account of deposits mad....
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....;Base Note' available with this office, of Shri. Mukesh D. Ambani (BUP ID 5090160984) it is clear that there are two bank accounts in the name of Canbar Holdings Corporation namely BUP ID 5090260976 and BUP ID 5091327690. Assessee the beneficial owner of HSBC Bank Foreign Account having Client / Profile (BUP ID 090260976) held in the name of Canbar Holdings Corporation. The previous year relating to the AY 2001-02 covers the period from 01/04/2000 to 31/03/2001. Thus, during the A.Y 2001-02, the assessee held foreign bank account which is an asset located outside India as provided for in proviso 2 to sec. 147 of Income Tax Act, 1961. Perusal of the return of income filed by the assessee for the year under consideration reveals that the assessee had not disclosed said foreign bank account in his return of income. The initial deposits made to open the bank account or thereafter in the relevant previous year along with income generated due to being the beneficial owner of such foreign bank account should have been disclosed in the said return of income for AY 2001-02, which has not been done by the assessee. As per available information a deposit of USD 1,00,000 (Approx) is to be ....
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.... BUP ID 5090260976 and BUP ID 5091327690 (even though, as per base note, 5091327690' is not BUP ID but it is client profile code), held in the name of CHC. According to ld. Assessing Officer, a deposit of USD 1,00,000 (approx.) is to be made to open such an account and cost of about USD 300 per year is incurred for maintenance. It was further observed from the Base Note of the assessee that customer profiles of Flag Telecom Grp Ltd ("Flag Telecom") and First Corporate Director Inc. ("FCDI") were related to the assessee. Since, the assessee did not disclose these bank accounts in his return of income for AY 2001-02, income therefrom escaped assessment. 3.2. Assessee objected to the re-opening of the assessment, vide letter dated 06.08.2018, on the following grounds: a) Assessee did not hold any bank account in HSBC Bank, Geneva, in his name. b) Assessee was not aware of any understanding between his deceased father and Mr. M.K Shetty c) Copy of Base Note, its source and authenticity were not provided by the ld. Assessing Officer d) In order to avoid undue adverse publicity of the deceased, Shri Dhirubhai H Ambani (Shri DHA), legal heirs (i.....
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....A and the two legal heirs. Accordingly, he considered one third proportion to assess income in respect of the said bank accounts, in the year under consideration. Accordingly, he made additions u/s. 69A of the Act as unexplained money for the captioned Assessment Year, to the total income of the assessee, as under: Sr .N o. Particulars Reference Amount Substantive Additions Protective Additions Assessee's share (1/3rd ) Others' share (2/3rd) For the bank account with alleged BUP ID 50902 60976 1. Maintenance Charges USD 300 (Rs.13,992) USD 100 (Rs.4664) USD 200 (Rs. 9328) 2. Initial Deposit USD 100,000 (Rs. 46,64,000) USD 33,333 (Rs. 15,54,667) USD 66,667 (Rs. 31,09,333) USD 33,433 (Rs.15,59,331/-) USD 66,867 (Rs.31,18,661/-) 3.5. As can be seen in para 16 to 19 of the impugned assessment order, ld. Assessing Officer has held that the alleged initial deposit of USD 100,000 and annual expenses of USD 300 is assessable amongst the assessee, his deceased father and assessee's brother in equal proportion. While making substantive additions, ld. Assessing Office....
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....Dhirubhai Ambani was the beneficiary and the balance in the said account has devolved on his two legal heirs Mr. Mukesh D. Ambani and Mr. Anil D. Ambani. It is also seen from the information forwarded to me that vide letter dated 30th June 2011, HSBC PVL Bank, Geneva has informed Mr. Mukesh D. Ambani that "we can confirm that neither at the time of data theft nor today, you or RIL have been or are the holder or from our records, the beneficial owner of any account with our book in Switzerland" 2. It is also seen that no original return for period under question, i.e., A.Y. 2006-07 has been filed by Mr. Dhirubhai Ambani as he had passed away before the relevant previous year. However, a return for A.Y. 2006-07 declaring income of Rs. 24,73,46,660/- (with SA Tax has been filed in name of Late Shri Dhirubhai H. Ambani by his two sons on 09.08.2011 in my office, in their capacity as Legal Heirs. 3.7. It is important to note that Base Note referred by the ld. Assessing Officer for the purpose of making addition in all the three cases, viz. Late shri DHA, the assessee and Shri Anil D. Ambani is the same. It is from this common document that additions have been made in the han....
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.... ID 5090260976 maintained in HSBC Bank, Geneva and maintenance cost incurred on such bank account by disregarding the fact that the foreign bank account was not disclosed in his Return of Income? 2. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in not considering the BUP ID as account number, by placing reliance on the decision of the ITAT Mumbai in the case of DCIT vs Kumar Rasiklal Mehta [2022] IΤΑ No. 438 to 442/Mum/2022; however in the case of Kumar Rasiklal (supra), the Hon'ble ITAT Mumbai had not deliberated on whether BUP ID is to be considered as a separate bank account number or not. 3. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the substantive and protective addition made on account of initial deposit made by the assessee in the foreign bank account having BUP ID 5090260976 maintained in HSBC Bank, Geneva, by disregarding the fact that the assessee had refused to give consent to the HSBC Bank, Geneva in favour of the department, so that necessary record could be received from the HSBC Bank and the necessary additions would have been made....
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....y of the 'Base Note' available with this office, in the case of Shri Mukesh D Ambani (BUP ID 5090160984) and Shri Anil D Ambani (BUP ID 5090160983) it is clear that there are two bank accounts in the name of Canbar Holding Corporation namely BUP ID 5090260976 and BUP ID 5091327690. Further as per the copy of the Base Note available with this office in the case of Shri Mukesh D Ambani (BUP ID 5090160984) and Shri Anil D Ambani (BUP ID 5090160983), there was HSBC Bank foreign account having Client/Profile (BUP ID 5090260976) held in the name of Canbar Holdings Corporation also separate from the Account No. 1327290 mentioned by Shri M K Shetty. The previous year relating to the AY 2001-02 covers the period from 01.04.2000 to 31.03.2001. Thus during the AY 2001-02, the assessee held foreign bank account which is an asset located outside India as provided for in proviso 2 to section 147 of the Income Tax Act 1961. Perusal of the return of income filed by the assessee for the year under consideration reveals that the assessee had not disclosed said foreign bank account in his return of income. This initial deposits made to open the bank account or thereafter in the relevant previ....
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....essing officer stated that the assessee filed objection to the reopening the assessment and the same has been rejected vide order dated 22.11.2018. Subsequently, a show cause notice u/s 142(1) of the Act was issued on 19.12.2019 to the legal heirs of the assessee, the extract of the same is reproduced as under: "You are required to show cause as to why addition should not be made in the hands of the assessee with regards to the undisclosed foreign bank accounts as mentioned in the reasons for reopening of the assessment provided to you, for the initial deposit of USD 1,00,000 required for opening each account and cost of USD 300 per year incurred for maintenance of each account". 4. In the assessment order the assessing officer mentioned that assessee filed reply to the show cause notice. However, the assessing officer had not discussed the contents of the reply filed by the assessee in the assessment order. The AO stated that information was received by the Government of India from the French Government that some Indian Nationals and residents have foreign bank accounts in the HSBC Bank, Geneva, Switzerland which were undisclosed to the Income Tax Department. The....
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....ining such account. On query, the legal heirs of the assessee submitted that they had filed return of income on 09.08.2011 on behalf of the assessee i.e. Late Shri Dhirubhai H. Ambani for financial year 2005-06 and declared an income of Rs. 24,73,46,660/- and had paid taxes of Rs.14,09,59,731/-. The legal heirs had also submitted that there was only one account in the HSBC Bank Geneva linked to their father in the name of Canbar Holding Corporation a/c no. 5091327690. It is also submitted that legal heir had declared the aforesaid bank account and HSBC Bank Geneva in the hands of the late father Shri Dhirubhai H. Ambani for the financial year 2005- 06 and offered to income in the hands of late Shri Dhirubhai H. Ambani. However, the AO stated that the assessee had not provided complete date wise details of transactions in the above mentioned account and also not offered any income in respect of the other account in the name of Canbar Holding Corporation having BUP ID 5090260976. The legal heir of the assessee had denied of any such BUP ID 5090260976 bank account maintained as alleged by the AO. However, the AO concluded that as per the Base Note available with his office, there were....
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....ontend existence of the other account. The examination of this note reveals the following: I. The first page of the 'Base Note' shows basic details of the client profile code of Canbar Holding Corporation (CHC) and Flag. The relevant extract of the Base Note is as under: The above extract shows details of client profile code, bearing no. 50913 27690, such as date of creation, date of closure, status, nature of profile, type of profile. Further, at the right side of the details of client profile code it also shows: ● "Patrimoineconstatéendecembre 2005" meaning thereby "Assets (account balance) noted in December 2005", the same for 2006; and ● "Patrimoine max constaté sur la periode", meaning "Maximum assets observed over the period", noting the same in November 2005." II. The above profile letter of Mr. MK Shetty which recorded the account number as 1327690. The Base Note also records the maximum balance in November 2005 over $5 million. III. On perusal of the entire Base Note, no such details are found for the other account, as alleged by the AO, bearing no. BUP ID 50901 60976. This number only ....
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....at any maintenance charges is required to be incurred to maintain such an account. 7.6 A further reference can be made to the decision of Hon'ble Mumbai Tribunal in case of DCIT v. Kumar Rasiklal Mehta [2022] ITA No. 438 to 442/Mum/2022, wherein the Base Note showed BUP ID and Client Profile Code for entity in question. However, in that case the assessing officer had made addition u/s. 69A only for the client profile code and did not make any adjustment for the BUP ID. Therefore, the conclusion that the BUP ID is not a separate bank account is supported by this decision as well. Hence, such a presumption is fallacious. 7.7 Even otherwise, the AO does not appear to have given any specific basis for arriving at conclusion regarding requirement of initial deposit of $1,00,000 and maintenance charges of $300. Even it is assumed that it is a separate bank account opened with an initial deposit of $1,00,000, in that case the initial deposit would have been reflected as a balance in the Base Note. However, no such details related to this BUP ID is reflected in the Base note. In such circumstances, I am of the view that the appellants contentions appears to be correct that no ....
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.... business identification no. of the Canbar Holding Corporation. The ld. DR placed reliance on the decision of Renu T. Tharni Vs. DCIT of ITAT, Mumbai and stated that decision of ITAT Mumbai in the case of Kumar Rasikhlal Mehta is not applicable. The ld. DR also submitted that Ld. CIT(A) has ignored the fact that there was no rational in taxing the peak balance of the undisclosed bank a/c in assessment year 2006-07. The ld. DR also submitted that Base Note received from the French Government was never available with the AO at the time of earlier assessment proceedings and the foreign bank a/c with HSBC bank Geneva having BUP ID 5090260976 was undisclosed. 7. On the other hand, the ld. Counsel submitted that as per letter of Mr. M.K. Shetty there was only one a/c which was opened i.e. 5091137690 and this account was dormant and same was closed in 2006. The ld. Counsel further submitted that as alleged by the AO other account bearing no. BUP ID 5090260976 was not bank account and the same was only ID of the Canbar Holding Corporation relating to the a/c no. 509137690. The ld. Counsel also referred the different details mentioned on the copy of Base Note placed in the paper bo....
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....he legal heirs. The AO opined on the basis of unspecified information of public domain that initial deposit USD 1,00000 and maintenance charges USD 300 were required for keeping such bank account. Accordingly, the AO has added the above referred deposit and maintenance charges amount to the total income of the assessee and assessed the same in the equal proportion in the name of Shri Dhirubhai H. Ambani, Shri Mukesh Ambani and Shri Anil Ambani on the substantive bases and assessed 2/3 amount on protective basis. The AO has completed the assessment u/s 143(3) r.w.s 147 of the Act for the assessment year 2001-02 to 2006-07. The detail of computation made by the assessee along with similar nature of addition made in all the years are reproduced as under: I. AY 2001-02 Sr. No. Description of item BUP ID 5090260976 (Amount) 1. Initial deposit USD 100,000 2. Maintenance Charges USD 300 3. Total USD 100,300 4. Substantive Additions (1/3rd of Total amount) Rs. 15,59,331 5. Protective Additions (2/3rd of total amount) Rs.31,18,661 6. Total Additions 46,77,992 II. AY 2002-03 Sr. No. Description of item ....
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....O in reopened assessment proceedings on the basis of Base Note opined that these were the two bank account in the name of Canbar Holding Corporation bearing BUP ID 5090260976 and 5091327610 as discussed. 10. The AO opined that aforesaid bank a/c bearing BUP ID 5090260976 was not disclosed by the assessee in the return of income filed. The AO was of the view that the initial deposit made to open these accounts along with maintenance charges and income generated on such account should have been disclosed in the return of income. In this regard the AO had neither disproved the submission of the assessee nor established that assessee had paid the alleged initial deposit amount to open the bank account along with maintenance charges. We have also gone through the Base note showing basic detail of client profile code of Canbar Holdings Corporation Ltd. The relevant extract of the base note is as under: 11. In the Base note pertaining to BUP ID 5091327690 there was also BUP ID 5090160976 appeared under the heading "Autres Personnes Liees Aux Profiles clients which in English mean that other people linked to client profile". On perusal of the base note it is noticed that ....
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....r other particulars like the case of the assessee available in the base note. In that case ITAT also held that addition of initial deposit was made on surmises which stand merged in the balances shown carried forward. It is clear from the facts and material discussed that (BUP id) 5090260976 was merely a business partner identification number for the entity and there existed no separate account. 11.3 We find the decision of ITAT, Mumbai in the case of Renu T Tharani vs DCIT (International Taxation) (2020) 117 taxmann.com 84 (Mumbai) relied upon by the ld. DR are distinguishable from the case of the assessee. In that case the assessee was clearly beneficial owner of deposit in foreign bank account showing Rs. 196 crores peak amount based on Base Note. In that case the assessee has not explained the contents of the Base Note and claimed that assessee was a non-resident and was chargeable to tax only on income which accrues or arises in India. Whereas in the case of the assessee it was explained after referring the relevant material that customer profile 5091327690 for account holder Canbar Holding Corporation mentioned in the Base Note showing maximum peak balance of USD 55,....
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....the CIT(A) on the above ground be set aside and that of the Assessing Officer be restored. 5. The appellant craves leave to amend or alter any ground or add a new ground which may be necessary." 13. The assessee has filed return of income declaring total income of Rs.8,99,65,840/- on 29.07.2002. The case of the assessee was reopened u/s 147 of the Act by issuing of notice u/s 148 of the act on 26.03.2019. In the reason recorded for reopening the AO has mentioned about the assessment year 2001- 02 which has been reopened on the basis of information received as per Base Note that assessee was beneficiary of foreign bank account with HSBC bank. The AO was also of the view that there were two bank accounts in the name of Canbar Holding Corporation having BUPID 5090260976 and BUP ID 5091327690. The AO has also referred the submission made by the authorized representative before the DGIT (Inv) Mumbai that the assessee late Shri Dhirubhai H. Ambani had opened foreign bank account with HSBC Bank Geneva in the year 2001-02 with BUP ID 5091327690. 13.1 Similar to assessment year 2001-02 as discussed supra after referring unspecified information available in the pub....
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....ppeal filed by the assessee vide ITA No.4331/Mum/2024 AY: 2001-02 and vide ITA No. 4324/Mum/2024 AY: 2002-03 as discussed supra in this order, therefore, applying the finding of the same mutatis mutandis this appeal of the revenue is also dismissed. ITA No. 4347/Mum/2024 AY: 2004-05 15. On similar issue on identical fact, we have dismissed the appeal filed by the assessee vide ITA No.4331/Mum/2024 AY: 2001-02 and vide ITA No. 4324/Mum/2024 AY: 2002-03 as discussed supra in this order, therefore, applying the finding of the same mutatis mutandis this appeal of the revenue is also dismissed. ITA No. 4346/Mum/2024 AY: 2005-06 16. On similar issue on identical fact, we have dismissed the appeal filed by the assessee vide ITA No. 4331/Mum/2024 AY: 2001-02 and vide ITA No. 4324/Mum/2024 AY: 2002-03 as discussed supra in this order, therefore, applying the finding of the same mutatis mutandis this appeal of the revenue is also dismissed. ITA No.4345/Mum/2024 AY: 2006-07 17. On similar issue on identical fact, we have dismissed the appeal filed by the assessee vide ITA No.4331/Mum/2024 AY: 2001-02 and vide ITA No. 4324/Mum/2024 AY: 2002....
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.... 21. Before us the ld. Counsel submitted that reopening of assessment from A.Y. 2001-02 to A.Y. 2005-06 was time barred as section 149(1)(c) could not be applied to the assessment which had attained finality before the date of operation of clause (c) i.e. 01.07.2012. The ld. Counsel has also placed reliance on the various judicial pronouncement as per the copies of decision placed in the paper book. He also submitted that in respect of deposit in HSBC Bank A/c 5091327690 assessment has already been duly completed for the A.Y. 2006-07 and the observation of initial deposit and maintenance are merely based on assumption without any relevant material. 22. On the other hand, the ld. DR has referred the amended provision of section 149 of the Act, 1961 and contended that same shall be applicable for any assessment year beginning on or before the 1st day of April, 2012. 23. Heard both the sides and perused the materials on record. We have perused the provision of section 149 as amended vide Finance Act, 2012 through which reopening upto sixteen years is enabled in cases where income in relation to any asset located outside India chargeable to tax has escaped assess....
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....preme Court was dismissed vide order dated 05.07.2019. Following the decision of the Hon'ble Delhi High Court and the decision of the ITAT Mumbai as discussed the cross objection no.2 that limitation period expired for reopening the assessment which had already attained finality before the amendment is allowed. 25. Therefore, following the settled judicial findings as discussed we consider that reopening of assessment for A.Y. 2001-02 to A.Y. 2005-06 are not valid. Therefore, cross objection no. 2 filed for A.Y. 2001-02 to A.Y. 2005-06 are allowed. The assessee has filed identical cross objection in all the years on the ground that reassessment proceedings were void in absence of any income which escaped assessment as the peak balance of A/c No. 5091327690 (being client profile code as per base note) was already offered and assessed to tax in the hands of late Shri Dhirubhai Ambani in A.Y. 2006-07. In this regard, we find that reopening of assessment in respect of client code no. 5091327690 is not valid since the same has already been reopened and taxed in A.Y. 2006-07 vide order dated 13.01.2012 passed u/s 143(3) r.w.s. 147 of the Act, therefore, similar cross ob....
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....been referred as Customer Profile ID, In fact, in all the items listed in Base note, account number are not mentioned as BUP ID. 3.4. As per international practice of banking, the Assessee understands that BUP ID is a Business Partner Identification assigned to the entity itself. Whereas, bank account number is different from the said BUP ID and is linked with the same. 3.5. Accordingly, the Assessee submits that from the Base Document, only one bank account appears with one BUP ID and bank account number. 3.6. This is further confirmed from details mentioned in the same Base Note, under the heading "Autres Personnes Liees Aux Profils Clients", which in English would mean "Other people linked to customer profiles" for other entities. The screenshot of the same is as under: 3.7. In all the above cases, there is one BUP ID mentioned against the name field, which starts with '5090'. There is another ID mentioned against the Customer Profile, which starts with '5091'. This is irrespective of whether the name of the customer is same with the profile name. Hence, it is evident that the BUP ID is like a customer relationship number and t....
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....ssessee, one BUP ID 5090260976, second BUP ID 5091327690 and the third BUP ID 5090160984 and made the additions with respect to these three alleged accounts in HSBC Bank. For the alleged bank accounts at Sr. No.1 and 2, the matter has been already extensively dealt by the Co-ordinate Bench (supra). Facts specific to the assessee in respect to these two alleged BUP IDs have already been discussed in above paragraphs. 7. In respect of the BUP ID at Sr. No.3, similar assertions are made by the assessee explained and corroborated from the base note and relevant material placed on record. Relevant portion from the submissions made by the assessee in this respect is extracted below: "18. As regards the BUP ID 5090160984, it/only appears at one place in the Base Note, which is extracted as underThe above field appears to contain personal details such as date of birth, place of residence, sex, marital status, etc. It is logical to contain a business partner identification number along with such details. Besides, the BUP ID 5090160984 is quoted under the heading "identifiers internes" which translates in to "internal identifiers". A business partner identification no. which is a....
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....peal filed by the Revenue vide ITA No. 5141/Mum/2024 AY: 2001-02 as discussed supra in this order, therefore, on similar issue on identical facts, applying the finding of the same mutatis mutandis, all the other captioned five appeals of Revenue are also dismissed. 10. In the result, all the six appeals of the Revenue are dismissed. Cross Objection Nos. 233/M/2024 to 238/Mum/2024 11. Since all the six cross objections filed by the assessee are based on identical issues on similar facts, therefore, these objections are adjudicated together by taking the cross objection No. 233/M/2024 as lead case and its findings will be applied mutatis mutandis to the other cross objections. Cross Objection No. 233/M/2024 12. The cross objection filed on the validity of reopening assessment is as under: 1. Erred in not quashing the re-assessment order dated 30th December 2019 passed u/s. 143(3) r.w.s. 147 of the Income-tax Act, 1961 ("the reassessment order"). 2. Erred in not quashing the reassessment order by holding that the notice issued u/s. 148 was barred by limitation, as the period of limitation u/s. 149(1)(b) had expired on 31st March 2008, and as such claus....
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....31 2: 32 28 66: 2: 46 77 992 200.000 300 1.00, 300 : 00 300 2 AV 2002-03 (TA 5140/MUM/2024; CO 235/Mum/2024 30.00% Rs. 26.26,667 Rs. 9,01.92.906 Rs 4,880 (1/3rd of USD 300 Rs. 18,60,207 Rs 9.36.84,662 Rs 18,73,69,324 R$ 28,10,53,986 R$ 4.880 RX 9 750 2: 48.80.000 R$ 14,640 Rs. 48,94,640 [1/3rd of USD) 100.000 (1/3rd of USD) 55.44,646 (1/3rd of USD) 1.14,358 (1/3rd of USD 57,59,304) (2/3rdof USD 5759.304) (USO 57,59,304) (1/3rd of USD) 300 (1/Ind of USD 300 .50:00.000 USD 300 (USD 100,300 3 AY 2003-04 ITA 5123/MUM/2024, CO 234/Mum/2024 30.00% Rs. 4,750 Rs. 19,75,495 Rs 19,80,245 Rs 39,60.490 Rs 59,40,735 Rs 4,750 A: 4,750 ৳ 24250 43 14,252 Rs. 14,252 (1/3rd of) USD 300 [1/3rd of USO 1.24,755 (1/3rd of USO 1.25.055 (2/3rd of USD) 1.25,055 (USD 1,25,055) (1/3rd of USD) 100 [USD 300) (USD 300 4 AY 2004-405 ITA 5121/MUM/2024, CO 236/Mum/2024 30.00% RS. 4,344 Rs. 20,15,414 Rs 20,19,758 Rs. 40,39,516 Rs 60,59.274 R$ 4,344 R: 4344 R$ 13,033 R$ 13,033 (1/3rd of USO 300 (1/3rd of USD] 1.39,171 (1/3rd of US0 1,39,471) (2/3rd of USD 139.47 (USD 1,39,471 300 300 [USD 300) [USD 300] 5 AY 2005-06 ITA 5118/MUM/2024, CO 237/Mum/2024 30.00% Rs. 4,....
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....1426311]=> Allomey [STRIKIEN] Première adresse Nom (code GUP) KHURANA BHAG WAN DAS S (509018 21 55) Profils chents concernés FLAG TELECOM GROUP LIMITED |5091425311] => Amoney [ATTORNEY D / GROUP AT SEE MANNER OF SIGIN. IN THE FILE] Première adresse [non naferevocar] Nom [code BUP) MATHRUBCIO THES WARAN SUNDAR (5090182157) Profils clients concernes Première adresse -FLAG TELECOM GROUP LIMITED [50-9142631 1] => Attorney |STRIKEN] [non référence] Nam (code BWP) MC CORMACK EDWARD (50901-81034) Profils clients concerner Promlière adresse FLÅC TELECOM GROUP LIMITED (5091426311] => Attorney [ATTORNEY B / GROUP A / SEE MANNER OF SIGN. IN THE FALEI [non référence] Nam (code BUP) GALLAGHER PATRICK TERENCE (5090181036) Profils clients concernés Première adresse FLAG TELECOM GROUP LIMITED [50914.26311] => Allamey JATTORNEY CJ GROUP A / SEE MANNER OF SIGN, IN THE FILE! (non référence] Nom (code BUP) HSBC PRIVATE BANKING (GSAD) LONDON (5090271542) Prollis clients concernis Première adresse FLAG TELECOM GROUP LIMITED: [5091426311] => Leller of authorisation [non référencé] Nom [cade BUP) FLAG TELECO....