https://www.taxtmi.com/caselaws?id=431686 CBDT Instruction No. 5051 dated 07.02.1991 does not protect an accused from prosecution merely because he had crossed 70 years when the complaint was filed; the relevant date is the date of commission of the offence. Applying that principle, the Court treated the alleged non-disclosure of an undisclosed foreign bank account as referable to the earlier period when the account was opened and concealment occurred. Since disclosure and a revised return were made only after departmental action had begun, the instruction could not be invoked to defeat criminal proceedings. The complaint and consequential proceedings were therefore left undisturbed, and the petition for quashing failed. en-us Fri, 16 Dec 2022 00:00:00 +0530 Mon, 27 Feb 2023 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431686 CBDT Instruction No. 5051 dated 07.02.1991 does not protect an accused from prosecution merely because he had crossed 70 years when the complaint was filed; the relevant date is the date of commission of the offence. Applying that principle, the Court treated the alleged non-disclosure of an undisclosed foreign bank account as referable to the earlier period when the account was opened and concealment occurred. Since disclosure and a revised return were made only after departmental action had begun, the instruction could not be invoked to defeat criminal proceedings. The complaint and consequential proceedings were therefore left undisturbed, and the petition for quashing failed. Case-Laws Income Tax Fri, 16 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431686