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of <h1>Immunity Under Section 245H(1) Cannot Be Granted For Gradual Income Disclosures Made After Being Cornered</h1> The Delhi High Court ruled against the Settlement Commission's grant of immunity from penalty and prosecution under section 245H(1) of the Income Tax Act. The Court clarified that immunity cannot be granted automatically when concealed income is disclosed, especially when disclosed in installments rather than in the original application. The crucial factor is when such income is offered, not merely that it was eventually disclosed. When evidence shows larger concealed income than initially disclosed, subsequent disclosures when 'cornered' during proceedings cannot be considered full and true disclosure. Tax authorities should note this precedent when making submissions regarding immunity applications.
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