Filing of return of income-New assessee-Declaration of substantial income in the initial assessment year-Effect thereof in earlier years-Clarification regarding
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Reopening of assessments: voluntary disclosure alone should not trigger reopening; cooperative new taxpayers will be treated sympathetically. A new assessee's first-time declaration of substantial income does not alone justify reopening earlier assessments or initiating roving enquiries; established reopening principles require independent grounds beyond voluntary disclosure. Although penal provisions for defaults like late filing and advance tax non-compliance continue to apply, the Department instructs officers to adopt a liberal, sympathetic approach toward taxpayers who come forward voluntarily and cooperate in enquiries, and to encourage early filing of returns without fear.
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.
Reopening of assessments: voluntary disclosure alone should not trigger reopening; cooperative new taxpayers will be treated sympathetically.
A new assessee's first-time declaration of substantial income does not alone justify reopening earlier assessments or initiating roving enquiries; established reopening principles require independent grounds beyond voluntary disclosure. Although penal provisions for defaults like late filing and advance tax non-compliance continue to apply, the Department instructs officers to adopt a liberal, sympathetic approach toward taxpayers who come forward voluntarily and cooperate in enquiries, and to encourage early filing of returns without fear.
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