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2021 (5) TMI 604 - HC - Income TaxBlack Money (Undisclosed Foreign Income and Assets) and Imposition of Tax - application is to grant exemption from filing court-fee and welfare stamp - beneficial interest in the shares - foreign asset - HELD THAT:- Insofar as the knowledge of the AO is concerned, it is the case of the revenue that it became aware of the foreign asset, said to have been held by the petitioner, via the Foreign Tax and Tax Research (in short “FT and TR”), division of the CBDT. Thus, we would like to have on record, the documents and the information, that FT and TR had in its possession, to enable us to fix a date of knowledge and, if at all, the provisions of the Act would apply in this case. We are of the view, to get to this point, the date of knowledge of FT and TR would be relevant. These aspects can only be examined once a counter-affidavit is filed on behalf of the revenue. We may also note that there are several other issues that have been raised, in the petition. Accordingly, issue notice.
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