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1 - 10 of 11 (1.16 seconds)Section 132 in The Income Tax Act, 1961 [Entire Act]
Harjas Rai vs Commissioner Of Income-Tax And Anr. on 28 April, 1981
13. A reference was also made to the case of Harjas Rai v. CIT , wherein a learned single judge held that Section 273A has to be liberally construed as it is intended to encourage voluntary disclosure of income. The facts of that case show that there had been no search in the premises of the assessee.
Tribhovandas Bhimji Zaveri vs Union Of India (Uoi) And Ors. on 8 September, 1993
17. Counsel for the Revenue invited my attention to the decision of the Supreme Court in the case of Tribhovandas Bhimji Zaveri v. Union of India [1993] 204 ITR 368 in support of the submission that the disclosures made subsequent to a search are not voluntary. The Supreme Court at page 376 of the report observed that the declaration of the concealed income made after the books of account or other documents or valuable assets have been seized cannot be said to be a voluntary disclosure. It is so because the documents and assets seized would disclose to the assessing authority the concealment of income. Such concealment could have been in respect of the previous year in which the seizure was made or in respect of any previous year prior thereto.
Section 139 in The Income Tax Act, 1961 [Entire Act]
Section 271 in The Income Tax Act, 1961 [Entire Act]
Section 273 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Bhairav Lal Verma vs Union Of India (Uoi) on 17 October, 1997
12. Counsel also referred to the word "voluntarily" in Section 273A(1)(b) and submitted by placing reliance on the decision of a Full Bench of the Allahabad High Court in the case of Bhairav Lal Verma v. Union of India [1998] 230 ITR 855, submitted that the word "voluntarily" in Section 273A of the Act means out of free will without any compulsion and the assessee's disclosure being one made without any compulsion even before the detection of the concealed income by the Income-tax Officer, the disclosure must be treated as voluntary. Counsel also relied on the decision to support his argument that it cannot be said as a principle of law that disclosure of concealed income after the day of search cannot be voluntary, as the disclosure may extend to matters which could not have been detected even after scrutiny of the material that was seized during the course of the search.