2026 (6) TMI 545

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....llowing grounds of appeal:- 1.In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the action of Id. DDIT/ADIT(Inv.) FAIU Jaipur, levying penalty under Section 42 read with Section 46 of Black Money (UFIA) and Imposition of Tax Act, 2015 of Rs. 10.00 lacs. The action of the Id. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please be granted by deleting the entire penalty levied by Id. DDIT/ADIT(Inv.) FAIU Jaipur and confirmed by Id. CIT(A). 2. In the facts and in the circumstances of the case and in law, the ld.DDIT/ADIT(Inv.) FAIU Jaipur has grossly erred in mechanically levying penalty under Section 42 read with Section 46 of the Black Money (....

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....t the assessee was neither resident nor taxable in India during his service at Dubai; that after shifting to India, the assessee did not earn any income in India, therefore, the assessee did not file any return of income; that the aforesaid amount of Rs. 7,86,852/- was credited to the account of the assessee which was deducted towards some retirement plan by his foreign employer when the assessee was in the job in Dubai, and that the said amount was credited by the foreign employer to the account of the assessee on maturity in the year under consideration, however, the assessee was not aware of the same. The assessee was under the bona fide impression that since the assessee had not earned any income during the Financial Year 2018-19, there....