Swiss Bank A/c: Once assessee provides reasonable explanation, onus shifts to revenue

Kamal Galani Vs. ACIT (ITAT Mumbai) Facts- The assessee was non-resident in India up to Assessment Year 1999-2000. Mr. Dipak Galani, brother of the assessee, opened account in 1998 with HSBC Bank. Assessment of the assessee was re-opened on the ground that income chargeable to tax has escaped assessment due to non-disclosure of existence of bank account in HSBC Bank. Assessee submitted that bank account in HSBC Bank was opened by his brother and his name was included as a second account holder. Further, brother of the assessee also filed a letter mentioning that the bank account is opened by h...