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TMI Blog2025 (4) TMI 791X X X X Extracts X X X X X X X X Extracts X X X X ..... belong to same Assessee's, having identical issues, the four appeals are heard and decided in this common order. BMA No.1/Del/2023 & 2/Del/2023 2. Ld. Counsel for the Assessee submitted that the Assessee's have challenged the order of the CIT(A) wherein the Ld. CIT(A) upheld the order of penalty imposed u/s 41 of the Black Money (Undisclosed Foreign Income and Assets)and imposition of Tax Act, 2015. Further submitted that the coordinate bench of the Tribunal in the quantum appeals filed by the Assessee's in BMA Nos. 1 to 4/Del/2022,has reduced the addition, therefore, the penalty imposed on the Appellants deserves to be computed accordingly. 3. Per contra, the Ld. DR has also agreed to the submission of the Ld. AR and sought for decidin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enalty is also required to be computedas per Section 41 of the Black Money (Undisclosed Foreign Income and Assets)and imposition of Tax Act, 2015 in so far as the additions sustained by the Tribunal. Therefore, we direct the Assessing Officer ("AO") to re-compute the amount of penalty and pass order accordingly in accordance with law. 6. In the result, appeal of the Assessee in BMA No.1 & 2/Del/2023 is partly allowed for statistical purpose. BMA No. 3 & 4/Del/2023 7. In the above appeals the Appellants have challenged the order of the CIT(A) sustaining the order of penalty of Rs. 10 lakhs each imposed u/s 43 of Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 as the Assessee has failed to furnish the in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... "Further, the penalty proceedings are also initiated u/s 43 of the Black Money Act as the assessee has failed to furnished the information of foreign income/assets held by him in his ITR filed for the AY 2012-13 to 2017-18 and kept on stating that he has no foreign account/income/assets when repeatedly asked by Investigation wing, New Delhi and also during the proceedings under Black Money Act. Notice for initiating the penalty proceedings as mentioned above is being issued separately as per the provisions of Section 46 of the Black Money Act." 10. From the above, it is observed that the AO has recorded the satisfaction for initiation of penalty proceedings u/s 43 of the Black Money Act only for AY 2012-13 to 2017-18 and no satisfaction ha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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