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    <title>2025 (12) TMI 544 - MADHYA PRADESH HIGH COURT</title>
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    <description>A reassessment initiated under s.147 was challenged on the ground that income disclosed under the Voluntary Disclosure of Income Scheme, 1997 was immune from further scrutiny and that the consequent notice under s.143(2) was contrary to the Scheme. The HC held that the Scheme only protects the declarant from being compelled to disclose the source of income and requires disclosure of correct income; it does not bar the department from reopening if it learns of higher income not covered by the declaration, nor does it deem extended income to be correctly declared. The objection based on later departmental instructions was rejected as inapplicable to a notice issued earlier. The writ was dismissed, leaving the assessee to raise objections in assessment and pursue statutory appeals.</description>
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    <pubDate>Wed, 03 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 544 - MADHYA PRADESH HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=783004</link>
      <description>A reassessment initiated under s.147 was challenged on the ground that income disclosed under the Voluntary Disclosure of Income Scheme, 1997 was immune from further scrutiny and that the consequent notice under s.143(2) was contrary to the Scheme. The HC held that the Scheme only protects the declarant from being compelled to disclose the source of income and requires disclosure of correct income; it does not bar the department from reopening if it learns of higher income not covered by the declaration, nor does it deem extended income to be correctly declared. The objection based on later departmental instructions was rejected as inapplicable to a notice issued earlier. The writ was dismissed, leaving the assessee to raise objections in assessment and pursue statutory appeals.</description>
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