https://www.taxtmi.com/caselaws?id=787098 Voluntary offer of income during a survey and its subsequent declaration in the return cannot be contested for non taxability for the first time at the Tribunal where foundational facts were not placed before earlier authorities. The Court applied principles limiting Tribunal intervention on mixed questions of fact and law absent foundational facts on record and noted statutory routes for revision of returns and limited scrutiny scope. Allowing a late challenge would undermine finality of admissions in returns. Outcome: the Tribunal was justified in upholding taxation of the declared sum and in declining to entertain the new plea; the appeal was dismissed on that basis. en-us Fri, 20 Feb 2026 00:00:00 +0530 Thu, 26 Feb 2026 07:35:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787098 Voluntary offer of income during a survey and its subsequent declaration in the return cannot be contested for non taxability for the first time at the Tribunal where foundational facts were not placed before earlier authorities. The Court applied principles limiting Tribunal intervention on mixed questions of fact and law absent foundational facts on record and noted statutory routes for revision of returns and limited scrutiny scope. Allowing a late challenge would undermine finality of admissions in returns. Outcome: the Tribunal was justified in upholding taxation of the declared sum and in declining to entertain the new plea; the appeal was dismissed on that basis. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787098