Effective opportunity to explain foreign bank credits required remand for fresh appellate consideration with supporting evidence.

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....Unexplained foreign bank credits were remanded for fresh consideration because the assessee had not received an effective opportunity to submit supporting evidence on their source. The notes state that pending criminal financial-offence proceedings, custody, and detention under a look-out notice justified granting one further opportunity in the interests of justice. The appellate order was set aside, and the Commissioner (Appeals) was directed to reconsider the credits after providing a proper hearing and allowing supporting evidence to be furnished.....