The AO took note that information had been received which related to the assessee having accounts in a bank in Geneva. The assessee in his statement recorded during the course of search, replied in the negative to a specific query whether the assessee had maintained any bank accounts abroad. The AO took the view that it was evident from the records that the assessee had opened or operated accounts in a bank in Switzerland, and that there were four such undisclosed accounts linked to the assessee, and computed the interest income from these four bank accounts for the year and brought it to tax u/s.69 of the Income-tax Act, 1961 as undisclosed interest income. The CIT(A) deleted the addition.

Tribunal held that for AY 2014-15, if the assessee was not owner of the amount lying in the bank account, the interest income could not be added in the hands of the assessee and that even otherwise if the Department got any information with respect to the ownership of the money lying in the bank account with the bank in Geneva, the provisions of Expl 2(d) to s.148 enabled the interest income to be added in the hands of the assessee and the time limit available was 16 years. (AY. 2012-13)