https://www.taxtmi.com/caselaws?id=438137 ITAT JAIPUR - AT upheld a substantive addition for the year the undisclosed foreign assets first came to AO's notice, dismissing protective additions and related departmental appeals for other years as not maintainable under s.3 of the Black Money Act. The tribunal found the foreign company's Place of Effective Management outside India, rendering it a non-resident under s.6 and its assets and income not taxable in India. Consequently, credits and dividends belonging to the non-resident company could not be added to the assessee's income and no tax liability could be fastened on the assessee in respect thereof. 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 ITAT JAIPUR - AT upheld a substantive addition for the year the undisclosed foreign assets first came to AO's notice, dismissing protective additions and related departmental appeals for other years as not maintainable under s.3 of the Black Money Act. The tribunal found the foreign company's Place of Effective Management outside India, rendering it a non-resident under s.6 and its assets and income not taxable in India. Consequently, credits and dividends belonging to the non-resident company could not be added to the assessee's income and no tax liability could be fastened on the assessee in respect thereof. Case-Laws Income Tax Thu, 13 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438137