DCIT vs Dipendu Bapalal Shah

Whether the addition of amounts in a foreign HSBC bank account as undisclosed income sourced from India is sustainable for a non-resident assessee --- Held No. Whether the Assessing Officer validly invoked Section 147 for reassessment based on information about a foreign bank account --- Held Yes, but the addition fails on merits. Whether the same income can be taxed twice in the hands of different assessees --- Held No, as it violates the principle against double taxation.