Voluntary tax compliance encourages liberal treatment of repentant taxpayers while preserving penalties for continued evasion.

Where a taxpayer's high Advance Tax estimate reflects accumulated untaxed income of prior years, officers should treat voluntary declarations sympathetically and avoid reopening earlier assessments unless material in their possession affirmatively shows past evasion that cannot be accounted for by the taxpayer's current-year estimates; this liberal approach is principally applicable where concealment in earlier years is not evidenced by tangible assets.

---

---

---