Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act additions.

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....The Black Money Act distinguishes undisclosed foreign income from an undisclosed foreign asset, and its deeming fiction for pre-commencement assets is confined to assets that remain unexplained. The notes state that foreign-bank credits supported by affidavits, plausible source explanations and corroborative material, including a family gift and an investment refund, cannot be treated as undisclosed merely because documentation is incomplete. Unrebutted affidavits cannot be rejected on suspicion where the revenue neither investigates the explanation nor cross-examines the deponents. On the stated facts, the deposits did not satisfy the definition of an undisclosed foreign asset, and the related additions were deleted.....