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    <title>1989 (3) TMI 151 - ITAT AHMEDABAD-B</title>
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    <description>Declarations and returns filed under the voluntary disclosure scheme were treated as valid for assessment, reassessment and statutory penalty immunity because the statute did not require perfection in every detail, and the Department had itself acted on the filings. Penalty proceedings that had already been dropped on the same accepted legal basis could not be revived in reassessment on unchanged facts where the earlier order had neither been recalled nor set aside, so the later penalties were found unsustainable.</description>
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      <description>Declarations and returns filed under the voluntary disclosure scheme were treated as valid for assessment, reassessment and statutory penalty immunity because the statute did not require perfection in every detail, and the Department had itself acted on the filings. Penalty proceedings that had already been dropped on the same accepted legal basis could not be revived in reassessment on unchanged facts where the earlier order had neither been recalled nor set aside, so the later penalties were found unsustainable.</description>
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