Advance tax does not replace filing a return; undisclosed income treatment and remand for fresh block assessment review.

Payment of advance tax does not replace the statutory duty to file a return disclosing total income, and failure to file the return can still permit treatment of the income as undisclosed in block assessment proceedings. The later Supreme Court clarification is noted as supporting that position. Because the Tribunal's view on the principal question was found to be incorrect, the connected issues could not be treated as finally concluded and required reconsideration. The impugned orders were set aside and the matters remanded for fresh consideration on all issues, with an opportunity to both sides.

---

---

Issues: (i) Whether payment of advance tax by an assessee dispenses with the obligation to file a return and precludes treatment of the relevant income as undisclosed income; (ii) whether the Tribunal's orders should be set aside and the matters remanded for fresh consideration on all issues.

Issue (i): Whether payment of advance tax by an assessee dispenses with the obligation to file a return and precludes treatment of the relevant income as undisclosed income.

Analysis: Payment of advance tax does not substitute the statutory requirement of filing a return disclosing total income for the relevant assessment year. Without a return, the assessing authority cannot examine the particulars of income and deductions. The later Supreme Court ruling clarified that failure to file the return, despite payment of advance tax, does not prevent the income from being treated as undisclosed for the purposes of block assessment.

Conclusion: The issue was answered against the assessee and in favour of the Revenue.

Issue (ii): Whether the Tribunal's orders should be set aside and the matters remanded for fresh consideration on all issues.

Analysis: Once the Tribunal's view on the principal question was found to be incorrect, the connected issues could not be safely segregated or treated as finally concluded. In a block assessment, the assessment has to proceed as an ordinary assessment in terms of the governing statutory mandate, and the remaining controversies required reconsideration with an opportunity to both sides.

Conclusion: The Tribunal's orders were set aside and the matters were remanded for fresh consideration on every issue.

Final Conclusion: The appeals succeeded on the principal legal question, the impugned orders were vacated, and the disputes were sent back for de novo consideration on all points.

Ratio Decidendi: Payment of advance tax does not relieve an assessee of the obligation to file a return, and failure to do so may justify treating the relevant income as undisclosed in block assessment proceedings; if the foundational view on that issue fails, interlinked matters may be remanded for fresh adjudication.

---