Hot!, is the word that can describe the current relationship of the Government of India, Income Tax Authorities, and those who have made disclosure of Foreign Bank accounts under The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (“Black Money Act”) and those who have failed to disclose their foreign bank accounts, income and assets, and information of which for one reason or the other, has come to the knowledge of the Income Tax Authorities. The knowledge of the Government of India might be based on various sources like Panama Papers, HSBC offshore leaks or information procured by the Government of India under the Exchange of Information clause of Double Taxation Avoidance Agreement(s) (DTAA) with different countries.   An opportunity was given by the Government of India for disclosure of the black money, foreign income and assets under the Black Money Act, but this opportunity came with a rider, i.e., the information of such bank accounts, foreign assets or income shall not be within the prior knowledge of the Government of India as provided under Section 71(d)(iii) of the Black Money Act. 

Please read the attached article on the subject.

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