News & Media 10th Jun 2025

Delhi High Court to decide if taxman can revive tax notices dating back to 1996 for foreign assets

Authors

Rahul CharkhaPartner | Pune

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Our Partner Rahul Charkha appears in the latest Mint article titled “Delhi High Court to decide if taxman can revive tax notices dating back to 1996 for foreign assets” by Krishna Yadav.

In the article, Mr. Charkha provides invaluable perspective on how retrospective reopening of tax notices under Section 148 especially relating to foreign assets could significantly undermine voluntary disclosure schemes under the Black Money Act, potentially deterring future participation. He says,

“Taxpayers use such schemes to regularise past non-disclosures with immunity from prosecution. If old assessments are reopened despite such schemes, it might deter future participation in similar initiatives.”

This is a critical development, as the Delhi High Court’s decision could set a precedent impacting compliance, fairness, and trust in India’s tax regime.

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