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Whether or not the learned CIT(A) was justified in upholding the addition in the hands of the assessee for Rs 1,96,46,79,146, being an amount equivalent to US $ 3,97,38,122 at the relevant point of time, held by HSBC Private Bank, Geneva, Switzerland, in the name of Tharani family trust, of which the assessee was a beneficiary.

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Sec. 147 of Income-tax Act, 1961 - Reassessment - If the AO for whatever reasons (material) has reason to believe that income chargeable to tax has escaped assessment then jurisdiction is conferred upon the AO to reopen the assessment". The expression "reason to believe" must obviously be that of a prudent person and it is on the basis of the reasons recorded by the AO that the question as to whether there was a reason to believe that income has escaped assessment, has to be determined. At the same time, the sufficiency of the reasons for reopening an assessment does not fall for determination, at the stage of a reopening of assessment". In the light of such legal position, ITAT held that credible information about existence of assessee’s account with HSBC (P) Bank Geneva with a peak credit of around Rs. 200 crores in the relevant financial year which is far disproportionate to her reported annual income and which is not taken into account in her return of income, the AO was perfectly justified in holding the view that the income has escaped assessment. Appeal of the assessee dismissed. - RENU T. THARANI V/s DY. CIT - [2020] 206 TTJ 521 (ITAT-MUMBAI)