evidence: Prior to introduction of Black Money Act, 2015 any undisclosed foreign asset was liable to be assessed as undisclosed investment under sections 69, 69B of the Income-tax Act, 1961. Such undisclosed foreign asset could have been brought to tax by invoking provisions of sections 147-148 etc. of the Income-tax Act, 1961 in case income escaping assessment comes to the knowledge of the Assessing Officer at a later date. It is also pertinent to mention that by way of amendment brought under section 149 of the Income Tax Act, by the Finance Act, 2012, time limit for issuing notice under section 148 of the Income-tax Act, 1961 was extended up to sixteen years from the end of the relevant assessment year in respect of the asset located outside India. Thus, there was a special mechanism and sufficient power with the Tax department for assessing or reassessing such undisclosed foreign asset under the Income-tax Act, 1961. [...] Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Rules, 2015 provides for the method of valuation of undisclosed asset located outside India. Rule 3 prescribes as to how fair market value of undisclosed foreign asset shall be determined. As per Rule 3(1), such asset is required to be valued on the valuation date when it comes to the notice of the Assessing Officer and the asset is existing as on that date.