The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (“Black Money Act”) was enacted with a clear goal — to unearth undisclosed foreign income and assets and discourage tax evasion. Fast forward 10 years and its implementation has sparked serious concerns about fairness and proportionality, especially for regular taxpayers instead of willful offenders. When Enforcement Overreaches Intent In recent years, the Income Tax Department has received extensive data on foreign bank accounts of Indian residents through the Exchange of Information provisions under Double Taxation Avoidance Agreements (DTAAs) and the Automatic Exchange of Information (AEOI) network.