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ITAT quashed assessment orders under Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 due to jurisdictional defects in notice issuance. The AO issued multiple notices under Section 10(1) for AY 2018-19, but per Section 72(c)'s deeming provisions, undisclosed foreign assets are deemed acquired in the year of notice issuance. Since notices were issued in 2018, assessments should have been for AY 2019-20, not AY 2018-19. The Tribunal held that without proper jurisdiction through valid notice, the AO couldn't pass assessment orders. The protective assessments of 50% amounts were invalidated due to this fundamental jurisdictional error.
ITAT quashed assessment orders under Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 due to jurisdictional defects in notice issuance. The AO issued multiple notices under Section 10(1) for AY 2018-19, but per Section 72(c)'s deeming provisions, undisclosed foreign assets are deemed acquired in the year of notice issuance. Since notices were issued in 2018, assessments should have been for AY 2019-20, not AY 2018-19. The Tribunal held that without proper jurisdiction through valid notice, the AO couldn't pass assessment orders. The protective assessments of 50% amounts were invalidated due to this fundamental jurisdictional error.
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