https://www.taxtmi.com/caselaws?id=343107 The Income Declaration Scheme, 2016 was held to be a limited fiscal arrangement that could not be enlarged by interpretation to cover persons expressly excluded by clause 196(e)(ii). Where search, requisition, or survey proceedings had been initiated and the statutory notice regime applied under the Income-tax Act, 1961, the exclusion remained operative, and the scheme could not override the Act's substantive provisions. Strict construction was applied, and no basis was found to create different classes based on whether disqualifying proceedings began before or during the scheme period. The assessee was therefore not entitled to the scheme's benefit, and the exclusion was upheld. en-us Fri, 24 Mar 2017 00:00:00 +0530 Sat, 18 Nov 2017 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343107 The Income Declaration Scheme, 2016 was held to be a limited fiscal arrangement that could not be enlarged by interpretation to cover persons expressly excluded by clause 196(e)(ii). Where search, requisition, or survey proceedings had been initiated and the statutory notice regime applied under the Income-tax Act, 1961, the exclusion remained operative, and the scheme could not override the Act's substantive provisions. Strict construction was applied, and no basis was found to create different classes based on whether disqualifying proceedings began before or during the scheme period. The assessee was therefore not entitled to the scheme's benefit, and the exclusion was upheld. Case-Laws Income Tax Fri, 24 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343107