TaxTMI 
TaxTMI 
2026 (7) TMI 1402
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....me Tax (A) 12, Hyderabad is not correct either on facts or in law and in both. 2. The Learned CIT(A) 12, Hyderabad erred in sustaining the addition of Rs. 1,17,96,000/- being foreign salary received from M/s Globex Holdings Pte Ltd, Singapore, which is taxable only in Singapore in terms of Article 15 of the India-Singapore DTAA since the appellant's stay in Singapore was less than 183 days. 3. Without prejudice, the Learned CIT(A)-12, Hyderabad erred in dismissing the claim for foreign tax credit of taxes paid in Singapore, as relief under section 90 of the Act read with the DTAA could not be denied when substantive evidence was available on record. 4. The Learned CIT(A)-12, Hyderabad, erred in upholding the a....
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.... well as the learned CIT(A) has granted sufficient opportunities to the assessee and even the additional evidence filed by the assessee before the learned CIT(A) was also forwarded to the Assessing Officer for remand report however, the assessee failed to explain the source of the credits in the bank account. He has relied upon the Orders of the authorities below. 5. We have considered the rival submissions and carefully perused the Orders of the authorities below. The Assessing Officer has made the addition of Rs. 2.63 crores on account of credits in the bank account of the assessee in SGD currency for want of explanation of the source. On appeal, though the assessee has filed some documents however, the same were not found to be satisf....
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....es posted for hearing on several occasions as mentioned above." 5.1. Thus, the learned CIT(A) has observed that despite various opportunities the assessee has not filed any response to the notice. Further, the learned CIT(A) has held in Para nos.6.5.10 to 6.5.15 as under: "6.5.10. The absence of any counter-submission from the appellant, despite due and adequate opportunity, implies that the appellant has not controverted or disputed the findings and observations made by the AO in the remand report. Hence, the contents of the remand report stand unrebutted and unchallenged, and the same are taken into consideration as part of the adjudication of this appeal. 6.5.11. After carefully considering the facts of the case, the....
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....nt was repeatedly given opportunities to present his case during the appellate proceedings, but he failed to appear or file any further evidence or counter-submissions despite several hearing notices, including a final notice dated 07.07.2025. 6.5.15. The appellant only sought time extensions on two occasions but ultimately failed to submit any explanation or documents. Since the appellant has not rebutted the findings of the Assessing Officer in the remand report, the observations made by the AO remain unchallenged and are taken into account for this decision. Given these facts, it is evident that the appellant did not discharge the burden of proof required under Section 68 of the Income-tax Act to explain the nature and source of....