2016 (5) TMI 798

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e above writ petition to issue a writ of certiorarified mandamus to call for the records of the respondent in C.No.407/11/2002-03 dated 13.02.2004 and quash the impugned order and consequently direct the respondent to grant relief to the petitioner for the assessment year 2000-01. 2. It is the case of the petitioner that it is a Partnership Firm consisting of four partners, engaged in the busin....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r Section 264 of the Income Tax Act and held that once the income is offered, then the same cannot be withdrawn. 3. Mr.R.Senniappan, learned counsel appearing for the petitioner submitted that the petitioner did not voluntarily admit an income of Rs. 25,00,000/- at the time of survey and that the statement was given only on the threat made by the respondent. The petition filed under Section 264....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he Hon'ble Supreme Court reported in 261 ITR 367 (SC) in the case of CIT vs. Shelly Products, wherein it has been held that the Act enjoins upon the assessee the duty to file a return of income disclosing his true income and the filing of the return and payment of tax thereon amounts to an admission of tax liability which the assessee admits to have incurred in accordance with the Act. 5. L....