No Black Money Liability When Assets Belong to Foreign Partner: ITAT Delhi

ACIT Vs Deepak Jain (ITAT Delhi) ITAT Deletes ₹31.48 Crore Black Money Addition for Lack of Beneficial Ownership; No Black Money Liability When Assets Belong to Foreign Partner: ITAT Delhi; ITAT Delhi Quashes Black Money Additions Based on Nominee Shareholding; Penalties Under Black Money Act Unsustainable When Asset Ceased Before 2012–13; Tribunal Holds No Jurisdiction to Tax Non-Existent Foreign Assets Under BMA; Revenue Cannot Switch from Income Tax Act to BMA: ITAT Delhi Applies Doctrine of Election; ITAT Delhi Rules BMA Inapplicable to Defunct Foreign Companies and Accounts Closed Bef...