Form 4 under the Income Declaration Scheme bars reassessment on the same declared income for alleged escapement.

Once Form 4 is issued under the Income Declaration Scheme in relation to declared income, that income is treated as regularised for the Scheme's purposes. A reassessment based on the very same declared amount lacks an independent basis for alleging escapement of income, so notices under sections 148 and 148A of the Income-tax Act, 1961, and related demand and penalty proceedings cannot be sustained. Where the Revenue accepts issuance of Form 4 for the declared amount, proceedings founded on that amount are without jurisdiction and liable to be quashed.

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Issues: Whether the reassessment proceedings initiated on the basis of income already declared under the Income Declaration Scheme could survive after issuance of Form 4 and whether the impugned notices and consequential orders were liable to be quashed.

Analysis: The declaration under the Income Declaration Scheme was not disputed, and the respondents' own affidavit accepted that the tax credit issue and correction of challan head would result in issuance of Form 4. Once Form 4 was issued, the declared income stood regularised for the purposes of the Scheme. The reopening was founded on the same declared amount and therefore the alleged escapement of income had no independent basis. In those circumstances, the foundation for the notices under sections 148 and 148A of the Income-tax Act, 1961, and the connected demand and penalty proceedings, could not be sustained.

Conclusion: The reassessment notices and consequential orders were without jurisdiction and were quashed, in favour of the assessee.

Ratio Decidendi: Where the revenue accepts issuance of Form 4 under the Income Declaration Scheme in relation to the declared income, reassessment on the very same declared amount cannot be sustained for alleged escapement of income.

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