Voluntary disclosure immunity is personal to the declarant and cannot be used by a Hindu undivided family.

Immunity under a voluntary disclosure scheme is confined to the declarant, so disclosures made by individual family members cannot be set off against additions in the assessment of a separate Hindu undivided family. The scheme granted benefit, concession or immunity only to the person making the declaration, and the Act treated an individual and a Hindu undivided family as distinct assessable units. The finding that the family members had no independent source of investment reinforced that only disclosures made in the assessee's own name could explain the disputed investments. The claim to use the members' disclosures was therefore rejected, and the position was held against the assessee and in favour of the Revenue.

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Issues: Whether the assessee-Hindu undivided family was entitled to set off disclosures made by individual family members under the voluntary disclosure scheme against additions made in the family's assessments.

Analysis: The voluntary disclosure scheme expressly confined any benefit, concession or immunity to the person making the declaration. The Act treated an individual and a Hindu undivided family as separate assessable units, and the scheme did not extend the declarations of individual members to the family itself. The finding that the members had no independent source of investment further supported the view that only disclosures made in the assessee's own name could explain the disputed investments.

Conclusion: The assessee was not entitled to claim the benefit of disclosures made by individual family members; the answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: Immunity under a voluntary disclosure scheme is confined strictly to the declarant, and disclosures by separate persons cannot be used to explain the unexplained investments of another distinct assessee, including a Hindu undivided family.

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