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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