Rationalisation of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015

Residence-based taxation clarified: expanded assessee definition and reassessment provisions to capture undisclosed foreign income and assets.

Amendments expand the definition of assessee to include residents in the relevant previous year and certain non-residents or not-ordinarily-residents who were resident either in the year the income relates to or in the year an undisclosed foreign asset was acquired, with acquisition year determined without applying a carry-forward provision; they also add 're-assess' and 'reassessment' terminology and make reassessment procedure from the income-tax framework applicable with modifications, while clarifying that the appellate authority may both increase and decrease penalties.