https://www.taxtmi.com/caselaws?id=793111 Penalty under section 43 of the Black Money Act was found unsustainable where foreign assets, though omitted from the original return under section 139(1), were disclosed in the return filed under section 153A after search and accepted in the assessment. The Tribunal applied the principle that a section 153A return substitutes the original return and that disclosure in that return cannot be ignored for penalty purposes. As no addition was made in the section 153A assessment and the record did not show deliberate tax evasion, the omission was treated as a bona fide technical lapse. Penalty was therefore not leviable on the facts. en-us Wed, 27 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793111 Penalty under section 43 of the Black Money Act was found unsustainable where foreign assets, though omitted from the original return under section 139(1), were disclosed in the return filed under section 153A after search and accepted in the assessment. The Tribunal applied the principle that a section 153A return substitutes the original return and that disclosure in that return cannot be ignored for penalty purposes. As no addition was made in the section 153A assessment and the record did not show deliberate tax evasion, the omission was treated as a bona fide technical lapse. Penalty was therefore not leviable on the facts. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793111