9911796707
TMI Blog2016 (7) TMI 402X X X X Extracts X X X X X X X X Extracts X X X X ..... nior Counsel (In all WPs.) For Mr.Suhrith Parthasarathy For the Respondents : Mr. T. Promod Kumar Chopda ORDER Heard Mr.V.T.Gopalan, learned Senior Counsel assisted by Mr.Suhrith Parthasarathy, learned counsel for the petitioner and Mr.T.Promod Kumar Chopda, learned Standing Counsel appearing for the respondents. 2. In the light of the stand taken by the respondents in their counter affidavit, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ew that the Commission does not have jurisdiction to entertain these applications offering undisclosed foreign income and assets. Since the Commission does not have the jurisdiction, we have not gone into the further question as to whether the Applicants have fulfilled the conditions u/s.245C. The order was pronounced in the court on 30.06.2015. 11.11 For the reasons discussed above, we do not a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... above two Applicants and we reiterate our findings given in the said order dated 30.06.2015 that since a resident's total undisclosed foreign income and asset will be dealt under the provisions of the New Act and not under the existing Income Tax Act (which will deal with disclosed foreign income of a resident which is part of the total Income Tax Act), the New Act imposes an implied repeal of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order dated 01.07.2015 followed by Explanatory notes dated 2.07.2015 issued in Circular No.12 of 2015 have clarified that the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 comes into effect from 1.07.2015. It is submitted that the Petitioner had filed Return of Income on 21.05.2015. Notice u/s.148 was issued by the Assessing Officer on 29.05.2015 which is, be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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