Opening of A/c in Foreign bank with Indian Passport- Indian Origin of deposit cannot be ruled out

DCIT  Vs. Rahul Rajnikant Parikh (ITAT Mumbai)

We note that at the time of opening of the bank account in Geneva, the assessee was a US citizen and resident and he was holding a US passport. Still the assessee chose to open the account in HSBC bank account in Geneva by using the address and proof thereof by way of his Indian passport which was no longer valid when he has accepted the US nationality by surrendering Indian citizenship. Here the assessee instead of surrendering his i

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