A K SONI Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) IN pursuance of the provisions contained in the Voluntary Disclosure of INcome and Wealth Act, 1976, the petitioner made some voluntary disclosures.

(2.) THE above statute deals with three types of voluntary disclosures. The first is covered by Section 3 of the Act. THE second type of disclosure is visualised by Section 14. This disclosure of income is for those cases where a search and seizure has been made. The third type of disclosure is dealt with by Section 15. This deals with voluntary disclosure of wealth.

(3.) LEARNED counsel appearing for the petitioner submits that the petitioner disclosed his income in terms of Section 14. It is submitted that in terms of Section 14(5), the immunity provided under Section 14(1) was not to be available to the declarant unless and until the tax chargeable in respect of the income of the previous year or years for which the declaration was made, was paid in accordance with the provisions of Section 5.