1 week ago
ITAT Rejects Tax Claim Over Rs 24 Crore Singapore Accounts
The tax department found Singapore bank accounts listed in Tarun Trikha’s name.
It said the money was an undisclosed foreign asset worth about Rs 23.91 crore.
Trikha said the accounts were not his and that someone had misused his identity.
He provided evidence connected to a criminal investigation.
The CIT(A) accepted his explanation and removed the tax addition.
The tax department appealed that decision.
The Delhi ITAT agreed that the department had not shown enough evidence that Trikha owned the accounts.
The ruling says that a person’s name on a foreign account is not always enough to prove ownership.
Genuine owners of undisclosed foreign assets can still face tax under the Black Money Act.
The Delhi ITAT upheld deletion of a Rs 23.91-crore foreign-asset tax addition against Tarun Trikha.
The tax department said Singapore bank accounts were linked to Trikha and represented undisclosed assets.
Trikha denied owning the accounts, saying his identity had been misused to create business and bank accounts.
The CIT(A) relied on identity-theft evidence, criminal proceedings and findings involving TVI Express Holidays.
The ITAT said the Revenue had not produced cogent material proving Trikha owned or controlled the funds.
- Who
- Tarun Trikha, the Income Tax Department, the Commissioner of Income Tax (Appeals), and the Delhi Income Tax Appellate Tribunal.
- What
- The Delhi ITAT dismissed the Revenue’s appeal and upheld deletion of a Rs 23.91-crore foreign-asset addition under the Black Money Act.
- Where
- The disputed accounts were in Singapore, and the case was decided by the Delhi bench of the Income Tax Appellate Tribunal.
- When
- The appeal was heard on June 3, 2026, and the order was pronounced on August 11, 2026, for assessment year 2021-22.
- Why
- The tribunal found that the Revenue had not provided sufficient evidence that Trikha owned or controlled the accounts, while identity-misuse evidence supported his denial.
Taxpayer’s Position
Revenue’s Position
Ownership of the accounts
Taxpayer’s Position
Trikha denied owning or controlling the Singapore accounts and said his identity had been stolen and used to create or operate business and bank accounts.
Revenue’s Position
The Revenue argued that the accounts were linked to Trikha and relied on information shared by Singapore’s competent authority with Indian tax authorities.
Evidence supporting the claim
Taxpayer’s Position
Trikha relied on an Economic Offences Wing complaint, a charge sheet and Special Court proceedings involving the alleged misuse of his identity through TVI Express Holidays.
Revenue’s Position
The Revenue argued that Trikha had not properly explained how his identity was stolen and that the criminal proceedings did not establish his position in the Black Money Act case.
Proof required for taxation
Taxpayer’s Position
The CIT(A) and ITAT found that the department needed stronger evidence showing actual ownership or control, not merely an account appearing in Trikha’s name.
Revenue’s Position
The Revenue maintained that the foreign-account information, Trikha’s alleged connection with TVI Express Holidays and the company’s Singapore operations supported treating the deposits as undisclosed assets.
Key facts
- Case
- DDIT (Inv.) 2(1), New Delhi vs Tarun Trikha, BMA No. 15/DEL/2025
- Assessment year
- 2021-22
- Alleged foreign assets
- Rs 23,91,64,565.91, or approximately Rs 23.91 crore
- Banks identified
- United Overseas Bank and Oversea-Chinese Banking Corporation in Singapore
- Tax law invoked
- Black Money Act, including Section 3(1) tax at 30 percent and Section 40 interest
- Tribunal outcome
- Revenue’s appeal dismissed; deletion of the addition upheld
- Central evidence
- Identity-misuse evidence, criminal proceedings, Trikha’s financial history, and the absence of sufficient contrary material
Quotes
Anita Basrur
Partner at Sudit K Parekh & Co LLP, commenting on the ruling’s implications.
“The authorities need to prove that the evidence is incorrect and that they have evidence to prove ownership to take the matter forward.”
financialexpress.com
“The information available is to be treated as a clue to investigate the factual matter.”
financialexpress.com
Sources
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