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5. We have carefully considered the rival submissions and have also gone through the order of the CIT as well other documents and circulars to which our attention was drawn during the course of hearing. The CBDT issued various circulars, e.g., Circular No. 423, dated 26th June, 1985 and Circular Nos. 432,439,440 and 441, dated 15th November 1985 and Circular No. 451, dated 17th February, 1986 regarding declaration of higher income or wealth which is commonly known as Amnesty Scheme announced by the CBDT. In all these circulars it was mentioned that where the tax payers voluntarily and in good faith make a true and full disclosure of his concealed income prior to its detection by the ITO, immunity will granted or a very liberal and sympathetic view will be taken in matters relating to levy of penalty, penal interest etc. In subsequent circulars issued from time to time it was assured that all assessees who come forward voluntarily to make a full and true disclosure of their income and wealth may avail this opportunity of voluntarily filing the returns of income and wealth without fear of any penal consequences such as penalty or prosecution. In all these circulars issued under the Amnesty Scheme there is no such specific guarantee or undertaking that the department will accept all these returns without any scrutiny or investigation. It has been indicated in these circulars that the disclosure should be honest, complete and true. In order to verify the correctness and completeness of such disclosure of income made in the returns of income submitted under Amnesty Scheme, the revenue could make necessary and relevant enquiries in appropriate cases.