An assessee has filed a declaration u\/s 4 of the scheme to settle the dispute that was being contested in an appeal before the Commissioner(Appeals) for A.Y. 2017-18 in respect of the addition made to the total income, under the Income tax Act, on the ground that the assessee owned an undisclosed asset located in a foreign country, outside India. An identical addition is also made under the provisions of the Black Money Act which is separately contested in an appeal under the BMA. The assessee seeks to settle the dispute under ITA by opting under VSVt and as a consequence thereof desires to persuade the appellate authority under the BMA that income once taxed can not be doubly taxed. The authorities have rejected the declaration by invoking the provisions of clause(iii) of sub-section(a) of s.9 .<\/p>\n","protected":false},"excerpt":{"rendered":"
An assessee has filed a declaration u\/s 4 of the scheme to settle the dispute that was being contested in an appeal before the Commissioner(Appeals) for A.Y. 2017-18 in respect of the addition made to the total income, under the Income tax Act, on the ground that the assessee owned an undisclosed asset located in a foreign country, outside India. An identical addition is also made under the provisions of the Black Money Act which is separately contested in an appeal under the BMA. The assessee seeks to settle the dispute under ITA by opting under VSVt and as a consequence thereof desires to persuade the appellate authority under the BMA that income once taxed can not be doubly taxed. The authorities have rejected the declaration by invoking the provisions of clause(iii) of sub-section(a) of s.9 .<\/p>\n