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    <title>2025 (2) TMI 48 - MADRAS HIGH COURT</title>
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    <description>Notices under Section 10(1) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 could not be sustained where the petitioners had already disclosed the assets and income in returns filed before 1 July 2015 and their disputes were later settled under Chapter XIX-A of the Income-tax Act, 1961. The High Court treated the subsequent acceptance by the settlement mechanism, together with departmental effect to that settlement and the compliance window noted in Circular No. 12 of 2015, as decisive. The Act was held to target undisclosed foreign assets not already brought within the earlier tax-disclosure framework, so the notices could not continue.</description>
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