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    <title>2025 (3) TMI 797 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that a joint-holder of foreign assets is not liable for penalty under Section 43 of the Black Money Act, 2015 when the beneficial owner has already disclosed the assets. The assessee was included as secondary owner for administrative purposes while his son was the actual beneficial owner who declared 100% ownership in his return. The tribunal found the assessee&#039;s belief that disclosure was not required was bonafide since the assets belonged to his son. The loan transaction between father and son occurred in India and was properly recorded, thus not covered under BMA provisions. The penalty of Rs. 10 lakhs for each of three years was set aside.</description>
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    <pubDate>Fri, 24 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 797 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=767411</link>
      <description>ITAT Mumbai held that a joint-holder of foreign assets is not liable for penalty under Section 43 of the Black Money Act, 2015 when the beneficial owner has already disclosed the assets. The assessee was included as secondary owner for administrative purposes while his son was the actual beneficial owner who declared 100% ownership in his return. The tribunal found the assessee&#039;s belief that disclosure was not required was bonafide since the assets belonged to his son. The loan transaction between father and son occurred in India and was properly recorded, thus not covered under BMA provisions. The penalty of Rs. 10 lakhs for each of three years was set aside.</description>
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      <pubDate>Fri, 24 Jan 2025 00:00:00 +0530</pubDate>
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