https://www.taxtmi.com/caselaws?id=800116 Section 72(c) treats a foreign asset acquired before commencement of the Act, where no Section 59 declaration was made, as acquired in the financial year in which the first Section 10 notice is issued. This statutory fiction operates by reference to the previous year, requiring assessment in the immediately succeeding assessment year. Where the first notice issued in Financial Year 2018-19, deemed acquisition falls in that year and is assessable only for Assessment Year 2019-20; an assessment for Assessment Year 2018-19 lacks jurisdiction. en-us Wed, 16 Sep 2026 00:00:00 +0530 Thu, 01 Oct 2026 07:40:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800116 Section 72(c) treats a foreign asset acquired before commencement of the Act, where no Section 59 declaration was made, as acquired in the financial year in which the first Section 10 notice is issued. This statutory fiction operates by reference to the previous year, requiring assessment in the immediately succeeding assessment year. Where the first notice issued in Financial Year 2018-19, deemed acquisition falls in that year and is assessable only for Assessment Year 2019-20; an assessment for Assessment Year 2018-19 lacks jurisdiction. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800116