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    <title>2026 (1) TMI 80 - BOMBAY HIGH COURT</title>
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    <description>Where a declarant under the Income Declaration Scheme, 2016 failed to pay the third instalment and, by virtue of s.197(b) of the Finance Act, 2016, offered the disclosed income to tax in a regular return and paid self-assessment tax, the HC held such payment was inextricably linked to the Scheme liability and, in substance, a payment towards the Scheme, reinforced by CBDT Circular No. 25/2016. The revenue&#039;s refusal to give credit and consequent non-issuance of Form-4 was arbitrary and unsustainable; the revenue was directed to treat the self-assessment tax as third-instalment payment, issue Form-4, and give effect under s.188 by reducing the declared income from the relevant assessment year and modifying the assessment and demand accordingly.</description>
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      <description>Where a declarant under the Income Declaration Scheme, 2016 failed to pay the third instalment and, by virtue of s.197(b) of the Finance Act, 2016, offered the disclosed income to tax in a regular return and paid self-assessment tax, the HC held such payment was inextricably linked to the Scheme liability and, in substance, a payment towards the Scheme, reinforced by CBDT Circular No. 25/2016. The revenue&#039;s refusal to give credit and consequent non-issuance of Form-4 was arbitrary and unsustainable; the revenue was directed to treat the self-assessment tax as third-instalment payment, issue Form-4, and give effect under s.188 by reducing the declared income from the relevant assessment year and modifying the assessment and demand accordingly.</description>
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