The petitions were filed questioning the competence of the PCIT ( Tamil Nadu and Puducherry) to sanction prosecution  for offences under S. 50 of the Black Money ( Undisclosed foreign Income and Assets ) and Imposition of Tax Act , 2015 to file the complaint against the petitioners. Petitions declare that S.48 and S.50 of the Black Money Act as unconstitutional and violative of Article 14 of  the Constitution of India . Allowing the petitions the Court held that ,  return of income has many schedules are part of  income referred to S.139 of the Act- Offence under S.50 of the Black money Act is made out only if, in the return of income under sub S. (1) or sub s.(4) or sub s.(5) of the income -tax Act , there has been a wilful  failure to disclosure any information relating to foreign asset .On facts the asset was disclosed in Schedule FA and in the case of Karti Chidambaram  , in the original return of income filed and other three cases in the revised return of income filed with in due date ; sanctioning authority has come to an erroneous conclusion that the case deserve prosecution for non-doscloure of the details of the asset in the return of income filed under S.139(1) . Sanction order was set aside , offences under S.50 is not made out consequently , complaints filed are quashed . However , contention of the assesses that the Principal Director of Income -tax is not an authority , jurisdiction /competence under S.55 of the Black  Money Act , to sanction prosecution or file a prosecution complaint for offences under S.50 of the Black Money Act is not accepted .    (WANos. 1125 to 1128 , review appl. Nos 79 of 2018 dt.2-11-2018.( AY. 2015-16 & 2016-17)