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2023 (4) TMI 201 - HC - Income TaxBlack Money (Undisclosed Foreign Income and Assets) - Proceedings triggered pursuant to the notice issued under Section 10(1) of the 2015 Act - information with regard to the fact that the petitioner was, perhaps, holding undisclosed assets in the British Virgin Islands came to light sometime in 2013 on account of an investigation carried out by the International Consortium of Investigative Journalists - Whether once the petitioner’s declaration under Section 59 of the 2015 Act was considered ineligible, then proceedings under the 2015 Act cannot be triggered - when did the respondents/revenue acquire tangible information with regard to the fact that the petitioner had held undisclosed assets? - HELD THAT:- The date on which the respondents/revenue acquired knowledge would then trigger the guidelines that the CBDT framed on 23.01.2018, which required it to issue notice under Section 10(1) of the 2015 Act within thirty (30) days of the end of the FY when it acquired such knowledge. Whether provisions of the 2015 Act would apply to those undisclosed assets which had been acquired prior to 01.07.2015? - Petioner at this stage, says that there are several other issues/grounds that the petitioner would want to put forth for consideration of this court. Mr Vohra says that the additional grounds find place in the writ petition. Matter requires further examination. List the matter on 27.04.2023.
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