Voluntary disclosure: limited immunity from past-assessment enquiries and penalties if tax and disclosures are timely made.

Reiterates that reopening past assessments is governed by Section 147, and that declaring substantially higher current-year income for advance-tax purposes alone does not justify initiating assessment proceedings for earlier years. The Board instructs a liberal administrative approach toward taxpayers who voluntarily disclose true income and wealth and pay tax thereon, withholding penalty and prosecution for such voluntary disclosures within the prescribed compliance period; penal measures remain reserved for cases where taxpayers are brought into the net by departmental effort.

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