Commissioner guidance under section 119(3) is advisory only; officers must apply independent judgment and avoid quoting advice. Section 271(4A) does not allow assessments or tax levies based on assurances between an assessee and Commissioners; Commissioners may give advisory guidance to Income-tax Officers under section 119(3) pending amendment, but such guidance is non-binding and subordinate officers must exercise independent judgment, may adopt the reasoning but should avoid quoting the advice in formal orders; voluntary disclosure determinations for penalty relief are to be judged by reference to factual replies and criteria in the cited Instruction.
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.
Commissioner guidance under section 119(3) is advisory only; officers must apply independent judgment and avoid quoting advice.
Section 271(4A) does not allow assessments or tax levies based on assurances between an assessee and Commissioners; Commissioners may give advisory guidance to Income-tax Officers under section 119(3) pending amendment, but such guidance is non-binding and subordinate officers must exercise independent judgment, may adopt the reasoning but should avoid quoting the advice in formal orders; voluntary disclosure determinations for penalty relief are to be judged by reference to factual replies and criteria in the cited Instruction.
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