Voluntary disclosure declarations bind the Revenue on status, while later tax consequences of declared assets remain assessable.

Acceptance of a declaration under the Voluntary Disclosure of Income and Wealth Act, 1976 gave the declarant the benefit of the scheme, and the Revenue could not displace the declared status merely by questioning the family's pre-existing source of income or assets. At the same time, the declaration did not prevent enquiry into the tax consequences arising later from the declared assets. The declared gold and the interest earned on the disclosed amount remained taxable in the hands of the declarant entity when the sale and accrual occurred. The finding that the Hindu undivided family was the declarant was upheld.

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Issues: Whether the Revenue could go behind a declaration made under the Voluntary Disclosure of Income and Wealth Act, 1976 and treat the declared assets and income as belonging to the individual rather than the Hindu undivided family.

Analysis: The declaration had been accepted by the competent authority and a certificate issued under the Voluntary Disclosure of Income and Wealth Act, 1976. The Revenue sought to displace the declared status on the footing that the family had no pre-existing source of income or assets. The reasoning applied the principle that immunity under the disclosure scheme is conferred on the declarant, while the declaration does not bar enquiry into the tax consequences of the declared assets at the later stage. The declared gold and the interest earned on the disclosed amount remained taxable in the hands of the declarant entity when the subsequent sale and accrual occurred.

Conclusion: The Revenue was not entitled to interfere with the accepted declaration, and the finding that the Hindu undivided family was the declarant was upheld.

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