2006 (3) TMI 82

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....tioner and, Mr. B.M. Chatterjee, learned counsel for the respondents. Rule. Returnable forthwith. By consent, rule is heard finally at this stage. On March 7, 2006, we passed the following order: "1. Inter alia, contention of Mr. Percy Pardiwalla, learned counsel for the petitioner is that on the application made by the assessee, the Commissioner granted certificate to the assessee set....

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.... certificate has not been cancelled. If that be so, we wanted to know from learned counsel for the Revenue how could the amount of voluntarily disclosed income be included in the total income of the assessee and how could the notice under section 148 of the Income-tax Act, 1961 be issued to the assessee. 3. Learned counsel for the Revenue prays for time to seek instructions. 4. Stand over fo....

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....d, granted the benefit of the said Scheme to the petitioner and a certificate was issued by the Commissioner under section 68(2) to the petitioner. That the certificate granted by the Commissioner under section 68(2) of the Voluntary Disclosure of Income Scheme, 1997 is still holding the field, is also not disputed by learned counsel for the Revenue. As a matter of fact, Mr. Chatterjee submitted b....