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1998 (9) TMI 3 - HC - Income TaxPenalty – concealment – search - disclosure – voluntary/involuntary - object of section 273A is to limit the reduction or waiver of penalty only to cases where the disclosure is voluntary, is in good faith, is full and complete and is made prior to the detection. The scope of the term "voluntarily" may vary depending on the context. Having regard to the context in which it occurs in section 273A(1)(b) and having regard to the scheme of the Act, it must be held to refer to disclosure made by the assessee wholly divorced from compulsion or provocation resulting from search and seizure. - Section 273A cannot be read as a charter for an assessee who has deliberately concealed his income to claim immunity from penalty after a search had been made in his premises and incriminating materials seized
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