The Income Tax department is being questioned for prosecution of Anil Ambani under the Black Money and Imposition of Tax Act, 2015, for allegedly evading taxes. The tax authorities were asked by the Bombay High Court, to explain how someone Ambani could've intentionally hidden his transactions, to evade a law which came into effect much later.

Anil Ambani has argued that the undisclosed transactions for $8.14 billion in Swiss Bank accounts that the IT department is prosecuting him over, were from 2006, 2007 and 2011, while the black money law was enacted in 2015.
The court asked if an act can be considered criminal, since the accused conducted transactions without knowing what the government would do in future.
Following this, the Bombay HC directed the income tax department against taking action against Anil Ambani, posting the matter to February 20.
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