A search and seizure operation was conducted on assessee’s premises and incriminating documentary evidence and information were discovered, establishing that assessee held undisclosed bank accounts and properties outside India.  Further, it was alleged that assessee was preparing to alienate his foreign assets and offshore entities by backdating documents to evade taxes under Black Money Act, 2015.  Accordingly, the Additional Commissioner of Income-tax (Central) had filed complaint under section    51(1)  of the  Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015.    Assessee filed  petition seeking quashing of criminal complaint filed against him on ground that prosecution was initiated without completing assessment proceedings, there was no finding that he had evaded any tax and there was no evidence showing that alleged foreign assets belonged to him. Dismissing the petition the Court held that initiation of prosecution is not dependent on completion of assessment, as offence, if proved, stands completed as soon as conditions as required under section 51(3) of are fulfilled, irrespective of return of income.An act of an assessee who is found to have undisclosed foreign income and assets,  amounted to preparation or attempt to evade tax, is  a matter for trial.