Direct beneficial interest in asset/ bank account is a pre-requisite for issuing Notice u/s 148

DCIT Vs Ganpat Singhvi (ITAT Mumbai) Conclusion: In present facts of the case, the only issue raised in the grounds of appeal is against the deletion of addition of Rs.5,30,92,953/- by Ld. CIT(A). The Hon’ble Tribunal uphold the observations of Ld. CIT(A) wherein it was observed that in order to assess the asset/bank account held by a third party in the hands of the respondent assessee the department has to prove that the assessee has direct beneficial interest in the asset/bank account held by third party. Facts: In present facts of the case, the Respondent is an individual residing in Abu ...