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 wa

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