No incriminating material on Swiss Bank Account, no addition: ITAT Delhi

Late Shri Bhushan Lal Sawhney Vs DCIT (ITAT Delhi)

Facts:

1. The IT Investigation wing had information that assessee maintained Swiss Accounts but this was vehemently denied by the assessee.

2. Swiss competent authorities provided information only from April 1, 2011. Earlier years (to which this litigation pertained) were not covered by the Exchange of Information Article in the India-Switzerland tax treaty and so account details for the relevant period was not provided by the Swiss authorities.

3. In 2007 an employee of HSBC Bank-Geneva obtained information on nearly 30,000 bank accounts and became a whistleblower and this case was based on the same information.

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