Where, in any income year, it appears from the statements filed by an assessee that the assessee—

(a) carries out any import or export and a discrepancy is observed between the actual transaction value and the declared amount paid or received for the import or export by the assesse; or

(b) makes any investment and the actual amount of money invested is found to be different than the amount of investment declared by the assessee, in that case, without prejudice to other provisions of this Act, tax shall be payable at the rate of 50% (fifty percent) on the difference mentioned in clause (a) or, as the case may be, on the difference between the amount of money actually invested and the amount of investment declared as mentioned in clause (b).