2025 (8) TMI 534

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....sed by the Assessing Officer, imposing penalty of Rs. 10,00,000/- u/s 43 r.w.s. 46 of the Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax Act, 2015, has been sustained, and his appeal stands dismissed. 2. Arguments heard. File perused. 3. Penalty order dated 29.05.2024 was passed on the ground that the assessee-appellant, while furnishing return of income for the assessment year 2015-16 did not disclose in FA schedule, foreign income to the tune of Rs. 10,00,000/- received by him from social security administration (United States). 4. As per case of the department, in order to open an enquiry on the above aspect, permission was obtained on 19.09.2022 and then summons were issued to the assessee u/s 131 of th....

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....urity received is in the nature of pension and it is received after deducting tax @ 30% (copy enclosed) from Social Security Administration, United States, hence, the amount so received is not taxable in India. 2. Further, I don't have any Financial Assets Outside India, therefore no information has been reported in Schedule FA of Income Tax Return for the AY 2015-16. you are hereby requested to drop the proceedings and oblige." 7. As is available from the observations made by the Assessing Officer in the penalty order, particularly in para 8, the assessee- Resident, did not disclose the above said foreign income in his return of income, especially in FA schedule. Main thrust of the Assessing Officer was on the aspe....