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    <title>1996 (6) TMI 52 - KERALA High Court</title>
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    <description>Section 154 rectification was held permissible where an earlier assessment order excluded income contrary to the statutory conditions of the Voluntary Disclosure of Income and Wealth Act, 1976. The scheme of section 3 applied only to qualifying declarants and qualifying income, while section 8 immunity from inclusion in total income operated only within the limits of that Act. A certificate under section 8(2) was conclusive only for that statutory framework. As the assessee&#039;s income and source were already recorded in the books and fell outside the intended class of declarants, the exclusion from assessment was a mistake apparent from the record and could be withdrawn.</description>
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    <pubDate>Thu, 20 Jun 1996 00:00:00 +0530</pubDate>
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      <title>1996 (6) TMI 52 - KERALA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=17906</link>
      <description>Section 154 rectification was held permissible where an earlier assessment order excluded income contrary to the statutory conditions of the Voluntary Disclosure of Income and Wealth Act, 1976. The scheme of section 3 applied only to qualifying declarants and qualifying income, while section 8 immunity from inclusion in total income operated only within the limits of that Act. A certificate under section 8(2) was conclusive only for that statutory framework. As the assessee&#039;s income and source were already recorded in the books and fell outside the intended class of declarants, the exclusion from assessment was a mistake apparent from the record and could be withdrawn.</description>
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      <pubDate>Thu, 20 Jun 1996 00:00:00 +0530</pubDate>
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