Scope of Comm.'s advice to subordinate officers in complicated matters.

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..... vy of taxes on the basis of contract or agreement between the assessee and/or the Commissioners giving the assessee assurances in the matter of penalty and prosecutions. 2. But in the spirit of the assurances given by the Finance Minister and Circulars No. 432, dated 20-9-85 and Circulars Nos. 439,440 and 441, dated 15-11-85 issued by the Chairman, it may be necessary for the Commissioners to gi .....

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..... is advice should be kept in view by the authority concerned in coming to a decision on the merits of the case in the light of his own judgement. While there can be no objection to such authority adopting the reasoning contained in the advice as his own, quoting or referring to the advice in the order that may be passed should be avoided." 3. Similarly, whether a disclosure was voluntary or not f .....

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