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Bdr Builders And Developers Private ... vs Assistant Commissioner Of Income Tax, ... on 1 May, 2024
cites
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 139 in The Income Tax Act, 1961 [Entire Act]
Section 153 in The Income Tax Act, 1961 [Entire Act]
Section 153A in The Income Tax Act, 1961 [Entire Act]
Section 151 in The Income Tax Act, 1961 [Entire Act]
Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd on 18 January, 2010
16. Learned counsel also submitted that since the AO had initiated
proceedings on the basis of fresh and tangible material received from
Investigation Wing, Delhi, it has strictly acted in accordance with the
tests laid down by the Hon‟ble Supreme Court in the case of CIT v.
Kelvinator of India Ltd. [2010 SCC OnLine SC 195].
Commissioner Of Income-Tax vs Bimal Kumar Damani on 10 February, 2003
"31. At this stage, we deem it necessary to expound on the meaning
of disclosure. As per the P. Ramanatha Aiyar, Advanced Law
Lexicon, Volume 2, Edition 6, „to disclose‟ is to expose to view or
knowledge, anything which before was secret, hidden or concealed.
The word „disclosure‟ means to disclose, reveal, unravel or bring to
Signature Not Verified
Digitally Signed
W.P.(C) 11908/2018
By:MAANAS JAJORIA Page 8 of 16
Signing Date:01.05.2024
17:04:47
notice, vide CIT Vs. Bimal Kumar Damani, (2003) 261 ITR 87 (Cal).
The word „true‟ qualifies a fact or averment as correct, exact,
actual, genuine or honest. The word „full‟ means complete. True
disclosure of concealed income must relate to the assessee
concerned. Full disclosure, in the context of financial documents,
means that all material or significant information should be
disclosed. Therefore, the meaning of „full and true disclosure‟ is
the voluntary filing of a return of income that the assessee
earnestly believes to be true. Production of books of accounts or
other material evidence that could ordinarily be discovered by
the assessing officer does not amount to a true and full
disclosure."
Honda Siel Power Products Limited vs Deputy Commissioner Of Income Tax on 23 December, 2015
ToVerified
Signature Not answer this pertinent query, reference can be made to the decision in
Digitally Signed
W.P.(C) 11908/2018
By:MAANAS JAJORIA Page 9 of 16
Signing Date:01.05.2024
17:04:47
Honda Siel Power Products Ltd. (supra), as discussed above, which
underscores that the material facts are those facts which if taken into
account would adversely impact the assessee by assessing a higher
income as compared to the original disclosure.
Techspan India Private Limited And Anr. vs Income Tax Officer on 24 February, 2006
In
any case, we find it apposite to place reliance on the decision of this
Court in Techspan India P. Ltd. v. Income-tax Officer [2006 SCC
OnLine Del 1754], whereby, it was held that every attempt to bring to
tax income that has escaped assessment cannot be thwarted by judicial
intervention on an assumed change of opinion. The relevant paragraph
of the said decision reads as under:-