The assessee was a resident senior citizen aged about 100 years and his son shri  Balaji Ramamoorthy  was a citizen of the United States of America. For the assessment year 2016-17 , the Assessing Officer issued notice under section 10(1) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 , calling for bank statements relating to investments of large sums in two United Kingdom-based trusts, Windsor Trust  and Dalham Trust , to explain the source of funds for making the investments. Not accepting the assessee’s explanation for the initial corpus invested in the trusts, the Assessing Officer made additions towards undisclosed investment. The Commissioner (Appeals) sustained the additions . On appeal the Tribunal held   that the sole basis for the Assessing Officer to arrive at the conclusion was the Common Reporting Standard information in the Department’s Insight portal showing the account balances in the two trusts, on the basis of which he concluded that the assessee being a settlor of the trust became the principal beneficiary and, consequently, the investment in the trust was undisclosed income of the assessee under section 10(3) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 . The Assessing Officer’s findings was not tenable for the simple reason that except for the Common Reporting Standard information, he did not have any other evidence to allege that the assessee had made contribution to the trusts. The Assessing Officer neither had the assessee’s bank statement to allege that the assessee had made outward remittance of funds nor could he prove that the assessee was deriving any income from the trusts outside India.  Investment in trust represented immovable property sourced through bank loan . Balance in other trust owned up and explained by assessee’s Non-resident son . Accordingly the  addition is deleted . (AY.2016-17)