S. Ravindra Bhat, J.

1. The question of law framed in this case is as follows:-

“Whether the order of the Tribunal deleting additions made by the Assessing Officer and confirmed by the CIT(A) relating to interest on bank accounts in UK and loan given by the assessee to Mr. N. Chhabra in UK is perverse, contradictory and based upon surmises and conjectures?”

2. The original assessee died even before the proceedings commenced.

3. The brief facts are that the assessee, Late Sh. K.M. Bijli [hereafter “Sh. Bijli”] was a tax payer. On the basis of an information received from the UK tax authority through letter dated 12.05.1989, in terms of the Indo-UK Double Taxation Avoidance Agreement [hereafter “DTAA”], the appellant/Revenue reopened the completed assessment for AY 1982-83 by reassessment notice dated 08.12.1992. Sh. Bijli died on 11.01.1992. The basis for the reopening of the completed assessment was a statement made by Bijli on 06.06.1983 to the UK revenue officials, who had suspected evasion of income on the part of one Sh. K.L. Kumar [hereafter “Sh. Kumar”] – Sh. Bijli’s brother-in-law. The communication received from the UK revenue authorities was that in the interview con