Assessee is an NRI filed his return of income and claimed exempt income towards interest received on NRE bank accounts and capital gains on sale of share.  As regards inward remittances the AO  treated the receipts from dubious companies mentioned in panama papers and accordingly   made additions under section 68  of the Act. On appeal the  assessee had filed additional evidence in form of certain e-mails between TII and its bankers, certificates of incumbency of two customers of TII to prove genuineness of said transaction. Tribunal held that   just because assessee had received money from a company based in BVI, it could not be taxed as unexplained credit, however the burden on assessee to prove the source. Accordingly the matter was to be remitted back to file of Commissioner (Appeals) with a direction to adjudicate on matter de novo after giving assessee one more opportunity to prove creditworthiness of said company and genuineness of transaction.  Tribunal also held that Article 24(1) can come into play only when discrimination is based on nationality,  if interest is wrongly charged by Assessing Officer, then just because assessee is a Portuguese citizen, it does not amount to non-discrimination under Indo-Portuguese tax treaty. (AY. 2016-17)