https://www.taxtmi.com/caselaws?id=305188 Where foreign assets are disclosed in a revised return filed within the time permitted under Section 139(5) of the Income-tax Act, wilful non-disclosure under the Black Money Act cannot be inferred merely because the revision followed a search or notice. The Court held that Sections 4 and 50 apply only when foreign income or assets are not disclosed in a return furnished within the time allowed under Sections 139(1), 139(4) or 139(5), and the presumption under Section 54 cannot substitute for the missing foundational element of wilful suppression. The criminal proceedings were quashed as the offence was not made out. en-us Fri, 24 Sep 2021 00:00:00 +0530 Tue, 22 Nov 2022 09:01:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305188 Where foreign assets are disclosed in a revised return filed within the time permitted under Section 139(5) of the Income-tax Act, wilful non-disclosure under the Black Money Act cannot be inferred merely because the revision followed a search or notice. The Court held that Sections 4 and 50 apply only when foreign income or assets are not disclosed in a return furnished within the time allowed under Sections 139(1), 139(4) or 139(5), and the presumption under Section 54 cannot substitute for the missing foundational element of wilful suppression. The criminal proceedings were quashed as the offence was not made out. Case-Laws Income Tax Fri, 24 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305188