SHYAM SUNDAR JALAN Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) WE have heard Shri Vikram Gulati, the learned counsel for the applicant and Shri Govind Krishna, the learned counsel for the opposite party. The following questions of law have been referred for opinion of this Court:

(2.) SHRI Vikram Gulati appearing for the assessee submits that since the assessee has made disclosure of income under the Voluntary Disclosure of Income and Wealth Act, 1975, the issuance of notice under S. 147(a) of the IT Act, 1961 ('the Act') is illegal and untenable and the reassessment made under the aforesaid provisions, should be declared void. For the purpose of this argument, we quote the following sections, viz., ss. 3 and 8 of the Voluntary Disclosure of Income and Wealth Act, 1975 which are as under :