TaxandTrade

The ITAT’s All-Things-Considered Approach   Background   This case has all the trappings of a thriller you would find in a Hitchcock movie.    From misdeclaration of residential status and address, the discovery of undisclosed foreign assets of huge sums and the sudden vanishing of these amounts, the order of the ITAT, Mumbai makes for a riveting read.    That the entire story of alleged evasion revolved around an 86-year old lady makes the issue even more intriguing.   It all started with the Income Tax department receiving certain information from Switzerland in Oct 2014 pursuant to treaty provisions.    The information was that Renu T. Tharani (Appellant) had a bank account in HSBC Private Bank, Geneva which showed a peak balance of USD 40 M in the FY 2005-06.       For that year, the Appellant had returned a paltry sum of Rs. 170,800 as Income in her returns.    It was the department’s contention that this bank account in HSBC Bank, Geneva was not considered in the return of income