2021 (10) TMI 274

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....1(1)(c) of the Act. 3. The fact in brief is that return of income of Rs. 67,85,155/- was filed on 21st Sep, 2013. The case was subject to scrutiny assessment and notice u/s. 143(2) was issued on 1st Sep, 2014. During the course of assessment vide letter dated 18th December, 2015, assessee stated that he was working in USA and was a non-resident Indian. His global income was taxable in India. The assessee returned India on 01-04-2007 and his global income became taxable in India since then. The assessee had not offered his global income in the income tax return of the subsequent year. The assessee had filed a declaration in Form no. 6 under the Black Money (undisclosed foreign income and assets) and imposition tax act 2015. The total of suc....

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....hi) and the decision of ITAT Delhi in the case of Addl. CIT-CC-14, New Delhi vs. Premchand Garg (2009) 31 SOT 97(Del). On the other hand, the ld. Departmental Representative has supported the order of lower authorities. 6. Heard both the sides and perused the material on record. During the course of appellate proceedings, the assessee filed letter before the Assessing Officer informing that he has filed a declaration in Form no. 6 under the Black Money (Undisclosed Income and Assets) and Imposition Act, 2015 and declared income of Rs. 12,18,459/- for the year under consideration. Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax 2015 was enacted for controlling and regulating the Black Money stashed abroad. It contain....

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....f section 60 of the Act. Black Money (Undisclosed Foreign Income and Asset) and Imposition Tax Rules, 2015 has also been into force which comprised 12 Rules and 7 Forms for making compliance. As per Rule 9(1), Form VI is pertained to making tax compliance for undisclosed asset located outside India under section 59 of the Act. The Act provides a one time compliance Scheme (OT CS) for a limited period (1.7.2015 to 30.09.2015), in accordance to the scheme a declaration may be filed before the specified tax authority within a specified period followed by payment of tax at the rate of 30% and an equal amount by way of penalty. The relevant issue in this case is about the acceptance of the Declaration filed by the assessee under the scheme. The ....