Section 15(5) in The Black Money (Undisclosed Foreign Income And Assets) And Imposition Of Tax Act, 2015
(5)The Commissioner (Appeals) shall hear and determine the appeal and, subject to the provisions of this Act, pass such orders as he thinks fit and such orders may include an order enhancing the assessment or penalty:Provided that an order enhancing the assessment or penalty shall not be made unless the assessee has been given a reasonable opportunity of being heard.
