Section 29(3) in The Black Money (Undisclosed Foreign Income And Assets) And Imposition Of Tax Act, 2015
(3)Notwithstanding that no appeal has been filed by a tax authority pursuant to the orders or instructions or directions issued under sub-section (1), it shall not be lawful for an assessee, being a party in any appeal, to contend that the tax authority has acquiesced in the decision on the disputed issue by not filing an appeal in any case.
