The Central Government has raised tax and penalty demands totalling Rs 35,105 crore under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (BMA), but has recovered only Rs 338 crore over nearly a decade, the Finance Ministry informed the Rajya Sabha on Tuesday.
In a written reply to a question, Minister of State for Finance Pankaj Chaudhary stated that 1,021 assessments were completed under the black money law as of March 31, 2025, resulting in 163 prosecution complaints being filed.
"From July 1, 2015, to March 31, 2025, recovery to the tune of Rs 338 crore has been made against tax, penalty and interest demand raised under the Act," said Chaudhary, highlighting the difficulty in realising dues under the law.
Legal Hurdles Slow Down Recovery
Pankaj Chaudhary clarified that many of the tax demands remain pending in appeal before various judicial and quasi-judicial bodies including:
- Commissioner of Income Tax (Appeals),
- Income Tax Appellate Tribunal (ITAT),
- High Courts,
- and the Supreme Court.
This legal backlog, along with complex asset-tracing processes, has been a major bottleneck in enforcement.
Surge in Indian Funds in Swiss Banks Raises Eyebrows
The disclosure comes in the backdrop of renewed public debate over Indian-linked funds in Swiss banks, which reportedly surged to CHF 3.5 billion (approx. Rs 37,600 crore) in 2024 - more than triple the previous year, according to data from the Swiss National Bank (SNB).
However, the government has dismissed these figures as misleading, arguing that SNB data includes inter-bank positions, fiduciary placements, and deposits of foreign branches, and is not a direct indicator of black money held by Indian residents.
Global Cooperation Through AEOI
India has been receiving detailed financial data from Switzerland and over 100 other jurisdictions under the Automatic Exchange of Information (AEOI) framework. The first exchange under this system took place in 2019 and has been occurring annually since then.
"Whenever tax evasion is detected through AEOI or other channels, appropriate action - including searches, surveys, assessments and prosecutions is initiated," Chaudhary added.
2015 Compliance Window: Rs 2,476 Crore Collected
The government also recalled the one-time compliance window provided in 2015 under the BMA, during which 684 disclosures of undisclosed foreign assets worth Rs 4,164 crore were made. This resulted in a collection of Rs 2,476 crore in taxes and penalties.
BMA Enforcement Summary (2015-2025)
| Metric | Figure |
|---|---|
| Assessments Completed | 1,021 |
| Tax & Penalty Demands Raised | Rs 35,105 crore |
| Amount Recovered | Rs 338 crore |
| Prosecution Complaints Filed | 163 |
| Disclosures During 2015 Window | 684 |
| Value of Disclosed Assets (2015) | Rs 4,164 crore |
| Tax & Penalty Collected (2015) | Rs 2,476 crore |
Enforcement Challenges Remain
While the Black Money Act, 2015, was introduced as a landmark legislation to combat offshore tax evasion, the low recovery rate after 10 years raises concerns about implementation and effectiveness. Experts point to lengthy legal disputes, difficulty in tracing foreign-held assets, and cross-border enforcement barriers as continuing obstacles.
Nonetheless, officials maintain that international cooperation, improved data access, and stronger domestic enforcement mechanisms are critical tools in India's ongoing battle against black money.
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