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    <title>2026 (8) TMI 46 - ITAT MUMBAI</title>
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    <description>A notice for assessment under the Black Money Act is described as time-barred where it was issued beyond the CBDT Guidelines&#039; preferred 30-day period following the relevant previous year. The notes state that information on the undisclosed foreign asset was available to the Department by April 2019, or at least when reopening reasons were recorded in March 2021, while the notice was issued in March 2022. As the delay lacked recorded reasons and approval from the competent authority, the guidelines were treated as binding on the Revenue. The consequential proceedings are described as null and void.</description>
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