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    <title>2026 (7) TMI 1711 - ITAT DELHI</title>
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    <description>Foreign exhibition-sale proceeds already assessed as business income in final settlement proceedings under the Income-tax Act cannot be reassessed as undisclosed foreign income under the Black Money Act, 2015. Income-tax Act assessments computed under the business-income provisions fall within the exclusion in section 4(2) of the 2015 Act, while section 4(3) prevents income included under that Act from also forming part of total income under the Income-tax Act. As the settlement order remained conclusive and unmodified, reassessment of the same foreign-sale income would constitute impermissible double taxation. Additions under the Black Money Act were therefore unsustainable, and deletions for the relevant assessment years were upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795825</link>
      <description>Foreign exhibition-sale proceeds already assessed as business income in final settlement proceedings under the Income-tax Act cannot be reassessed as undisclosed foreign income under the Black Money Act, 2015. Income-tax Act assessments computed under the business-income provisions fall within the exclusion in section 4(2) of the 2015 Act, while section 4(3) prevents income included under that Act from also forming part of total income under the Income-tax Act. As the settlement order remained conclusive and unmodified, reassessment of the same foreign-sale income would constitute impermissible double taxation. Additions under the Black Money Act were therefore unsustainable, and deletions for the relevant assessment years were upheld.</description>
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