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ITAT allowed the appeal, holding that amounts declared under IDS, 2016 (including advances and accrued interest received thereafter) constituted disclosed income and could not be taxed as unexplained income under s.68 read with s.115BBE. Having accepted the declaration filed under Rule 4, the taxpayer enjoyed statutory immunity conferred by the scheme and could not be compelled to disclose identities of counterparties; interest earned post-declaration until realization was held to be post-declaration income rather than undisclosed past income. Consequently, the AO's invocation of provisions treating the interest as unexplained income was set aside and the appeal in favour of the taxpayer was allowed.
ITAT allowed the appeal, holding that amounts declared under IDS, 2016 (including advances and accrued interest received thereafter) constituted disclosed income and could not be taxed as unexplained income under s.68 read with s.115BBE. Having accepted the declaration filed under Rule 4, the taxpayer enjoyed statutory immunity conferred by the scheme and could not be compelled to disclose identities of counterparties; interest earned post-declaration until realization was held to be post-declaration income rather than undisclosed past income. Consequently, the AO's invocation of provisions treating the interest as unexplained income was set aside and the appeal in favour of the taxpayer was allowed.
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