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2017 (9) TMI 188 - HC - Income TaxPrerequisite for an application u/s 245C(1) - Application to settlement commission - proof of full and true disclosure of income - sufficient details available suggesting full and complete disclosure - dealing in land transactions on behalf of others - failure to establish the identity of the third parties - Held that:- In the order dated 26.09.2016, the Settlement Commission has found that there was no full and complete disclosure of income so as to entertain an application for settlement. Based on the report of the Principal Commissioner of Income Tax, it was found that though the applicant sought to disclose the income of ₹ 32 crores through the application, in fact the income that ought to have been disclosed was ₹ 85 crores (rounded off). The finding of fact was arrived at by the Commission holding that in absence of full and true disclosure at the hands of the assessee, the application did not merit consideration. We do not find any reason to interfere in view of the narrow scope of judicial review to substitute our wisdom for the one taken by the Settlement Commission. The petition is, therefore, dismissed.
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