Case Law Details
DCIT Vs Vimal Kanubhai Patel (ITAT Ahmedabad)
Introduction: In the recent case of DCIT vs. Vimal Kanubhai Patel, the Income Tax Appellate Tribunal (ITAT) in Ahmedabad addressed a significant dispute concerning the addition of INR 3,45,90,531/- on account of unexplained credits in the Citibank NA Singapore account for the Assessment Year 2004-05. The Revenue, dissatisfied with the order of the Commissioner of Income-tax (Appeals) [CIT(A)], appealed against the decision.
Background: Vimal Kanubhai Patel, an individual and non-resident for the relevant assessment year, was a director in various companies, including Banco Product (India) Ltd. The investigation revealed undisclosed foreign assets, including bank accounts, investments, and properties. Patel admitted to non-disclosure before the investigation team and expressed the intention to determine taxable income related to these undisclosed foreign assets.
One of the undisclosed foreign bank accounts was with Citibank NA Singapore, jointly held with Patel’s brothers. The dispute primarily revolved around the credit entry in the Citibank NA Singapore USD account, amounting to US $7,87,939.73 during the assessment year 2004-05.
Revenue’s Grounds of Appeal: The Revenue raised two key grounds of appeal:
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