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2024-TIOL-81-SC-BM
IN THE SUPREME COURT OF INDIA
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DHANASHREE RAVINDRA PANDIT Vs ITD [High Court]
Special Leave to Appeal (Crl.) No(s). 11016/2024
INCOME TAX DEPARTMENT
Vs
DHANASHREE RAVINDRA PANDIT
Abhay S Oka & Augustine George Masih, JJ
Dated: August 23, 2024
Petitioner Rep. by: Mr Zoheb Hussain, Adv., Mr V Chandrashekhara Bharathi, Adv., Mr Bhuvan Mishra, Adv., Ms Astha Singh, Adv., Mr Raj Bahadur Yadav, AOR
Respondent Rep. by: None
Black Money (Undisclosed Foreign Income and Assets) Imposition of Tax Act, 2015 - Sections 10(1), 50 & 52; Code of Criminal Procedure - Section 200
Keywords - Retrospective application - Retrospective demand
ONE M/s Gleaming Snow Worldwide Limited was incorporated in the British Virgin Islands on 17.03.2008. Also, a M/s Oriental Success Universal Corporation, also a British Virgin Islands company, was incorporated on 12.05.2009. On 12.06.2009, Oriental Success Universal Corporation opened a bank account at UBS, Singapore, complying with local regulations including 'Know Your Customer' (KYC) requirements. Later, M/s Gleaming Snow Worldwide Limited was subsequently struck off in British Virgin Islands. During the FY 2010-11, M/s Oriental Success Universal Corporation received USD 16,000 and USD 40,000 in two transactions. The corporation was struck off in British Virgin Islands on 02-11-2010, and its M/s UBS Singapore bank account was closed after the financial year.
The Government of India introduced the Black Money (Undisclosed Foreign Income and Assets) Imposition of Tax Act, on Apr 01, 2016 and on...