2024 (12) TMI 859

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.... : Shri Hemanshu Joshi ORDER PER PRAKASH KANT [A.M.] :- These three appeals by the assessee are directed against the orders of the Learned Commissioner of Income-tax (Appeals), Mumbai-51 [hereinafter referred to as "CIT(A)"] passed in terms of section 16(7) of the Black Money (Undisclosed Foreign Income & Assets) and Imposition of the Tax Act, 2015 [hereinafter referred to as "BMA"], for ....

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....he learned Assessing Officer has erred in law and in fact by passing an assessment Order under Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. 2. The learned Assessing Officer has erred in law by imposing a penalty of Rs. 10,00,000/- on the grounds of alleged non-disclosure of Foreign Assets without appreciating the fact that employee....

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....ourse of finalization of the appeal proceedings." 2. The briefly stated facts of the case are that the assessee, who was employed with JP Marketing India Pvt. Ltd., had received restricted stock units listed in the USA Stock Exchange but same were not disclosed in the prescribed schedule of the Income tax return, and therefore, the AO levied penalty of Rs. 10,00,000/- each for AYs. 2019-20, 202....