| COURT: | ITAT Mumbai |
| CORAM: | R. C. Sharma (AM), Ram Lal Negi (JM) |
| SECTION(S): | 68 |
| GENRE: | Domestic Tax |
| CATCH WORDS: | HSBC Black Money, Undisclosed Income |
| COUNSEL: | Rohan Shah |
| DATE: | June 19, 2018 (Date of pronouncement) |
| DATE: | July 9, 2018 (Date of publication) |
| AY: | 2006-07 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| S. 68 HSBC Black Money: The assessee being non-resident is not liable to tax in respect of money lying in the foreign country unless the AO bring something on record to show that assessee has not fulfilled the test of taxability of non-resident under the provisions of the Act | |
We found that CIT(A) as dealt with the issue threadbare and after applying judicial pronouncements laid down by High Court and Supreme Court reached to the conclusion that assessee being non-resident is not liable to tax in respect of money lying in the foreign country unless AO bring something on record to show that assessee has not fulfilled the test of taxability of non-resident under the provisions of the Act. The detailed finding so recorded by CIT(A) are as per material on record and do not require any interference on our part
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