Held that once having denied the ownership of the accounts before the AO, the assessee cannot take a plea that no sufficient opportunity was allowed by the AO to explain the credit entries in the foreign bank account. Further, it is found that the CIT(A) also allowed sufficient opportunities to the assessee to explain the transactions in the foreign bank accounts by admitting the additional evidences filed before him. Assessee made submissions before the AO in the course of remand proceeding as well as before the CIT(A) after receipt of the remand report. Even if the CIT(A) passed his order within a month of the remand report, it is not the case that the he did not consider the submissions of the assessee on the rejoinder of the remand report. Rather, the CIT(A) passed a detailed order considering and taking into account the submissions of the assessee and substantially reduced the additions as made by the AO. Therefore, there is no instance of violation of natural justice in this case. The assessee was allowed sufficient opportunities to explain the transactions in the foreign bank accounts. (AY. 2000-01 to 2016-17)