https://www.taxtmi.com/caselaws?id=438137 Foreign company assets, investments and receipts could not be taxed in an individual's hands under the Black Money Act where the entity maintained separate books and the department failed to show that its funds were the assessee's personal funds. Mere fiduciary or signatory status, without corroborative evidence of funding or nexus with the asset, was insufficient to establish beneficial ownership. Amounts already reflected as inter-bank transfers, matured investments, contra entries or company income were not fresh taxable assets in the assessee's hands, and repeated inclusion would amount to double taxation. Protective additions for earlier years were held unnecessary where the same items had already been assessed substantively in the later year. en-us Thu, 13 Apr 2023 00:00:00 +0530 Tue, 07 Oct 2025 10:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438137 Foreign company assets, investments and receipts could not be taxed in an individual's hands under the Black Money Act where the entity maintained separate books and the department failed to show that its funds were the assessee's personal funds. Mere fiduciary or signatory status, without corroborative evidence of funding or nexus with the asset, was insufficient to establish beneficial ownership. Amounts already reflected as inter-bank transfers, matured investments, contra entries or company income were not fresh taxable assets in the assessee's hands, and repeated inclusion would amount to double taxation. Protective additions for earlier years were held unnecessary where the same items had already been assessed substantively in the later year. Case-Laws Income Tax Thu, 13 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438137