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Documents citing Principal Commissioner Of Income Tax - 9 vs Manju Osatwal on 11 February, 2022

Hemant Kumar Mulchandani, Jabalpur vs Dcit Circle 1(1), Jabalpur, Jabalpur on 29 November, 2022

The absence of any material to support the assessee's case being admitted, there must be something on record to exhibit the 'mistake', for which the surrounding circumstances and conduct become relevant, which we though find as consistent with the non-reporting of cash in IDS. The assessee before us relied on the decisions in Mahaveer Kumar Jain vs. CIT (CA No.4166/2006, dated 19/04/2018) and R. Natarajan vs. ACIT (ITA No. 1058/MDS/2010, dated 23/02/2012), to the effect that income cannot be taxed twice, and on Pr. CIT vs. Manju Osatwal [2022] 443 ITR 107 (Cal) and Gopalkrishnan Raj Kumar vs. Pr. CIT (in W.P.Nos. 6367 & 6374/2021, dated 22/04/2022) to the effect that where an income stands declared under disclosure (immunity scheme), the same cannot be subject to tax again.
Income Tax Appellate Tribunal - Jabalpur Cites 16 - Cited by 0 - Full Document

Ravi Kedia, Baloda Bazar, Baloda Bazar vs Income Tax Officer, Ward Bhatapara, ... on 25 May, 2023

11. Carrying his contentions further, it was submitted by the Ld. AR that as the P CIT, Raipur had accepted the disclosure made by the A.O under IDS, 2016, therefore, he had grossly erred in law by thereafter granting his approval to the A.O for reopening the case of the assessee for the said year u/s.147 of the Act. In support of his aforesaid claim, the Ld. AR had taken me through Section 189 and Section 193 of the Income Declaration Scheme, Finance Act, 2016. The Ld. AR further relied on the judgment of the Hon'ble High Court of Calcutta in the case of Pr. CIT Vs. Manju Oswal (2022) 443 ITR 107 (Cal.), wherein it was observed by the Hon'ble High Court that once a declaration made by the assessee under Income Declaration Scheme, 2016 (IDS) had been accepted by Principal Commissioner, such authority is thereafter estopped from taking any steps which would in effect amount to reopening and/or revising the decision already taken on such declaration.
Income Tax Appellate Tribunal - Raipur Cites 11 - Cited by 0 - Full Document
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