https://www.taxtmi.com/caselaws?id=175920 Liability to income-tax arises under the charging provisions, while assessment and recovery are machinery provisions. The Court held that an assessee may waive the ordinary assessment route and settle concealed income on an agreed basis where the department accepts the proposal and the arrangement is acted upon. On the facts, the assessee had accepted the settlement basis and made part payment, so a later attempt to repudiate it was not entertained in writ jurisdiction after the authorities had altered their position. The disclosure-based assessment was therefore treated as valid and the challenge failed. en-us Fri, 18 Dec 1953 00:00:00 +0530 Tue, 08 Dec 2015 17:31:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175920 Liability to income-tax arises under the charging provisions, while assessment and recovery are machinery provisions. The Court held that an assessee may waive the ordinary assessment route and settle concealed income on an agreed basis where the department accepts the proposal and the arrangement is acted upon. On the facts, the assessee had accepted the settlement basis and made part payment, so a later attempt to repudiate it was not entertained in writ jurisdiction after the authorities had altered their position. The disclosure-based assessment was therefore treated as valid and the challenge failed. Case-Laws Income Tax Fri, 18 Dec 1953 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175920