¹[19G. (1) Without prejudice to any other liability which may incur under any other provision of this Ordinance and any other law for the time being in force, where any person being a resident Bangladeshi is found to be the owner of any offshore asset not disclosed in the return and the assessee offers no explanation about the nature and source thereof or the explanation offered is not satisfactory, the Deputy Commissioner of Taxes shall, after ensuring a reasonable opportunity of being heard, proceed to recover from such person the amount of penalty equal to the fair value of such offshore asset.

(2) The Deputy commissioner of Taxes shall have the authority to recover the penalty under this section by confiscating or selling any asset held by or on behalf of the assessee.

(3) The Deputy of Commissioner of Taxes shall have the power to conduct an offshore investigation, where he has reason to believe that an assessee has offshore assets not disclosed in the return.

(3) To prevent holding undisclosed offshore asset and to recover such undisclosed asset, the Board shall have the power to-

(a) take necessary action as it deems fit; or

(b) allow, conduct, permit, arrange an inquiry or investigation by any income tax authority not being below the rank of Deputy Commissioner of Taxes.