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HC upheld the reopening of assessment u/s 147 and declined to quash the notice u/s 143(2). It held that under the Voluntary Disclosure of Income Scheme, 1997, the declarant is protected only from enquiry into the source of income, not from scrutiny of the correctness or completeness of the income disclosed. If higher income comes to the department's notice, the Scheme does not mandate acceptance of the declared figure. Alleged violation of Instruction No. 1984 was rejected as the instructions were prospective and issued after the impugned notice. The writ petition was dismissed, leaving the assessee to raise all objections before the AO and avail the statutory appellate remedies.
HC upheld the reopening of assessment u/s 147 and declined to quash the notice u/s 143(2). It held that under the Voluntary Disclosure of Income Scheme, 1997, the declarant is protected only from enquiry into the source of income, not from scrutiny of the correctness or completeness of the income disclosed. If higher income comes to the department's notice, the Scheme does not mandate acceptance of the declared figure. Alleged violation of Instruction No. 1984 was rejected as the instructions were prospective and issued after the impugned notice. The writ petition was dismissed, leaving the assessee to raise all objections before the AO and avail the statutory appellate remedies.
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