Penalty immunity for taxpayers who cooperate and make full and true disclosure, subject to withdrawal for concealment or false evidence. The Commissioner may grant conditional immunity from penalties to a person who applied for settlement and whose settlement proceedings abated, provided the application is made before any penalty is imposed after abatement and the person, after abatement, cooperated with the tax authority and made a full and true disclosure of income and its derivation; such immunity is withdrawable for non compliance with conditions or if the person concealed material particulars or gave false evidence, after which penalties apply as if no immunity had been granted.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Penalty immunity for taxpayers who cooperate and make full and true disclosure, subject to withdrawal for concealment or false evidence.
The Commissioner may grant conditional immunity from penalties to a person who applied for settlement and whose settlement proceedings abated, provided the application is made before any penalty is imposed after abatement and the person, after abatement, cooperated with the tax authority and made a full and true disclosure of income and its derivation; such immunity is withdrawable for non compliance with conditions or if the person concealed material particulars or gave false evidence, after which penalties apply as if no immunity had been granted.
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