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    <title>2026 (1) TMI 1506 - ITAT MUMBAI</title>
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    <description>Interpretation of the Black Money Acts scope focused on whether foreign shares acquired by automatic dividend reinvestment constitute &quot;undisclosed assets located outside India.&quot; The tribunal reasoned that the challenged receipts were dividend income with an explained source, and the deeming fiction that treats undisclosed assets as income applies to assets and not to income; conversion into shares by reinvestment does not change the character of the original receipt. Consequently, additions under the Act based on treating such shares as undisclosed foreign assets were found unsustainable and were deleted, with taxpayer relief granted.</description>
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      <title>2026 (1) TMI 1506 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=785750</link>
      <description>Interpretation of the Black Money Acts scope focused on whether foreign shares acquired by automatic dividend reinvestment constitute &quot;undisclosed assets located outside India.&quot; The tribunal reasoned that the challenged receipts were dividend income with an explained source, and the deeming fiction that treats undisclosed assets as income applies to assets and not to income; conversion into shares by reinvestment does not change the character of the original receipt. Consequently, additions under the Act based on treating such shares as undisclosed foreign assets were found unsustainable and were deleted, with taxpayer relief granted.</description>
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      <pubDate>Tue, 20 Jan 2026 00:00:00 +0530</pubDate>
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