Judgement under black money act
An undisclosed foreign bank account remains within the Black Money Act even if it was opened before the Act or closed later. It is taxed in the year it comes to the Assessing Officer's notice when its source is not explained.
UAE records showed an Emirates NBD Bank, Dubai account with an AED 5,000 credit and a 10% shareholding in Santech International FZE with AED 3,000 share capital.
The Dubai bank account and UAE company interest were not disclosed in the Income Tax Returns, Schedule FA or under the Black Money Act disclosure provisions.
Section 3 taxes an undisclosed foreign asset in the year it comes to the AO's notice. The information reached the AO on 25.04.2019, so AY 2020-21 was correct. Section 72(c) also covers pre-Act assets where no declaration was made. The source of the AED 5,000 was not proved with evidence.
Ashok Shankar v ACIT before Delhi ITAT