The Income Tax Appellate Tribunal (ITAT), Bangalore Benches, has ordered the consolidation of 26 appeals filed under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (Black Money Act), in a significant procedural move aimed at ensuring uniform adjudication of common jurisdictional and legal issues.
The matters have been clubbed together for a joint hearing before the C Bench on 10 August 2026, following requests made by both the assessees and the Revenue during proceedings.
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Common Jurisdictional Challenges Prompt Consolidation
During the hearing, the assessee’s authorised representative, Advocate V. Chandrashekhar, raised several jurisdictional objections relating to the validity of assessments, the applicability of various provisions of the Black Money Act, and the retrospective operation of certain statutory provisions. Similar jurisdictional and procedural issues were stated to be pending in several other appeals before the Tribunal, making a consolidated hearing desirable.
Bar Association Seeks Uniform Decision
The President of the ITAT Bar Association, V. Chandrashekhar, submitted before the Bench that all matters involving identical legal questions should be heard together so that the Tribunal could render a comprehensive and consistent decision after considering submissions from all affected parties.
The request found support from the Department as well. Smt. Divya K.J., CIT-DR, informed the Bench that the issues involved might require assistance from the Additional Solicitor General of India or other special counsel because of their wider implications under the Black Money Act.
Tribunal Directs Registry to Club All Connected Appeals
Accepting the submissions, the Tribunal directed its Registry to identify and club all connected Black Money Act appeals involving similar questions of law and list them for hearing on a common date. The Bench observed that such a course would facilitate an effective adjudication of the jurisdictional disputes and avoid conflicting decisions in similar matters. Consequently, the pending matters were adjourned to 10 August 2026, subject to the availability and appearance of the parties.
Twenty-Six Appeals Identified
The notice further states that, after considering the requests of the parties, the Registry identified 26 appeals for consolidation. These matters have been listed in Annexure A attached to the notice and include appeals filed by various assessees across the years 2024, 2025, and 2026 under the Black Money Act. The annexure includes cases relating to several taxpayers, including Martin Henry Clare Arne, Nikhil Ranjan Das, Ramnath Gupta Bysani, Dr. Kamini Rao, Dr. A.S. Aravind, Satish P. Chandra, and others, all of which are now scheduled to be heard together by the C Bench.
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