Court Rejects Plea to Apply Income Tax Act's 'Beneficial Owner' Definition to Black Money Act 2015 Due to Contextual Differences.

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....Scope of Black Money (Undisclosed Foreign Income & Assets) And Imposition of Tax Act 2015 - If we are to hold that definition of ‘beneficial owner’ as assigned by Explanation 4 to Section 139(1) is to equally apply, we will end up in a situation in which the BMA itself will become unworkable. Therefore, for both of these reasons- i.e. (a) the contextual requirements being otherwise, and (b) the adoption of this meaning rendering the provisions of BMA becoming unworkable, the definition under Explanation 4 to Section 139(1) cannot be adopted in the context of the BMA. We reject this plea of the learned counsel as well. - AT....