Exempt Salary Under DTAA Does Not Trigger Black Money Act: ITAT Chennai

Manikandan Rajapackiaeswaran Vs ACIT (ITAT Chennai)

Assessee is an individual who was deputed to Norway for a short duration of 3 months & received salary on which TDS was paid to the Norwegian Government. Assessee filed his return of income in India for AY 2016-17 but did not report salary received in Norway. AO invoked Black Money Act for AY 2022-23 although the alleged income pertains to AY 2016-17 & ACIT initiated proceedings u/s 10(2) of BM Act & treated Norwegian salary as “undisclosed foreign income & asset” u/s 3(1).

On appeal before the Tribunal,

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