Reassessment notices were issued on the grounds that the assessee deposited a huge amount of money in foreign bank accounts in Geneva but had not filed his return of income or explained the source of the deposits. The assessee explained that his nephew made the deposits. The Court noted that the provisions of sections 68 and 69 can only apply if there is an absence of explanation regarding the nature and source of income. The explanation offered by the assessee, in the opinion of the AO, was considered unsatisfactory. The Court held that the assessee had explained the nature and source of the investments. Also, the Tribunal noted that the assessee’s name was withdrawn from the account even before the notice was served. Further, the assessee was an agriculturist with only small land holdings and, therefore, could not have been in a position to make such huge deposits, especially in foreign currencies. The Hon’ble Supreme Court dismissed the Special Leave Petition. (AY.2006-07,  2007-08)