9911796707
TMI Blog2021 (5) TMI 604X X X X Extracts X X X X X X X X Extracts X X X X ..... e aware of the foreign asset, said to have been held by the petitioner, via the Foreign Tax and Tax Research (in short FT and TR ), division of the CBDT. Thus, we would like to have on record, the documents and the information, that FT and TR had in its possession, to enable us to fix a date of knowledge and, if at all, the provisions of the Act would apply in this case. We are of the view, to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bject to just exceptions. CM APPL. 16299/2021 2. The prayer made in the captioned application is to grant exemption from filing notarized affidavits along with the writ petition. The prayer made in the captioned application is allowed, subject to the petitioner placing on record the notarized affidavits, within three days of the resumption of the normal and usual work pattern by this Cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment order has already been passed. The impugned assessment order is dated 31.03.2021. 5.2 The petitioner has taken the position that much prior to the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (in short 'the Act') coming into force, the petitioner ceased to hold the foreign asset. 5.3. The petitioner claims that he had held beneficial intere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ia vs. Gautam Khaitan, 2019 (10) SCC 108. 6.2 Insofar as the knowledge of the AO is concerned, it is the case of the revenue that it became aware of the foreign asset, said to have been held by the petitioner, via the Foreign Tax and Tax Research (in short FT and TR ), division of the CBDT. 7. Thus, we would like to have on record, the documents and the information, that FT and TR had in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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