2022 (3) TMI 675

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....No.39/2022 C.M.Nos.11902/2022 & 11904/2022 in ITA No.40/2022 C.M.Nos.11907/2022 & 11909/2022 in ITA No.41/2022 C.M.Nos.11912/2022 & 11914/2022 in ITA No.42/2022 C.M.Nos.11918/2022 & 11920/2022 in ITA No.43/2022 Exemption allowed, subject to all just exceptions. Accordingly, the applications stand disposed of. C.M.No.11777/2022 in ITA Nos.37/2022 C.M.No.11813/2022 in ITA Nos.38/2022 C.M.No.11818/2022 in ITA Nos.39/2022 C.M.No.11903/2022 in ITA Nos.40/2022 C.M.No.11908/2022 in ITA Nos.41/2022 C.M.No.11913/2022 in ITA Nos.42/2022 C.M.No.11919/2022 in ITA Nos.43/2022 Keeping in view the averments in the applications as well as the Covid-19 pandemic and the fact that the appellant had filed applications ....

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.... Bank. The Appellant-assessee was requested to furnish the details of account opening form in respect of the foreign bank account, complete bank statements in original since beginning and residential status as per the Act as on the date of opening of the above mentioned foreign Bank Accounts. In the alternative, the Appellant-assessee was served with a notice calling upon her to co-operate and, inter alia, fill a consent-cum-waiver form. The form is set out in the documents annexed to these appeals and requires the Appellant-assessee's consent to enable the tax authorities to obtain information from Swiss Bank in respect of bank accounts held there. The Appellant-assessee disputes that she was ever an account holder in the Swiss banks. 3....

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....Mr. Sanjay Dalmia is reproduced hereinbelow:- ".......This Court has considered the submissions of the parties. The material on the record indicates that the French official source shared information with the Indian Government with respect to accounts held in HSBC Bank. Prima facie, such material disclosed that the assessee was an attorney of some account holder. In the Court's opinion, if the assessee really had no connection with such accounts, no prejudice could really have ensued to him if he would have complied with the notice under Section 142(1) of the Act and filed the consent form. In these circumstances, the penalty cannot be held to be erroneous or unwarranted. No question of law arises. The appeals are dismisse....