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    <title>2026 (3) TMI 1213 - ITAT KOLKATA</title>
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    <description>The BMA was applied prospectively from A.Y. 2016-17, with its proviso permitting only limited retrospective valuation of undisclosed assets acquired from income chargeable under the Income-tax Act. The Tribunal treated the notice and assumption of jurisdiction under section 10 as invalid where the assets or income were not undisclosed within the BMA, particularly when foreign assets or income had been disclosed through revised returns or voluntary letters. It also held that inherited corpus was an explained capital receipt and that historic interest income for pre-2016 years could not be taxed under the BMA, but only under the Income-tax Act machinery. Relief was granted to the assessee.</description>
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      <title>2026 (3) TMI 1213 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=788458</link>
      <description>The BMA was applied prospectively from A.Y. 2016-17, with its proviso permitting only limited retrospective valuation of undisclosed assets acquired from income chargeable under the Income-tax Act. The Tribunal treated the notice and assumption of jurisdiction under section 10 as invalid where the assets or income were not undisclosed within the BMA, particularly when foreign assets or income had been disclosed through revised returns or voluntary letters. It also held that inherited corpus was an explained capital receipt and that historic interest income for pre-2016 years could not be taxed under the BMA, but only under the Income-tax Act machinery. Relief was granted to the assessee.</description>
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