1999 (4) TMI 10

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....vant year? 2. Whether, there was any material before the Tribunal to hold that the income computation by the Department aggregating to Rs.53,054 in respect of the three years under consideration was justified?" Shri Vikram Gulati, appearing for the assessee, submits that since the assessee has made a disclosure of income under the Voluntary Disclosure of Income and Wealth Act, 1976, the issuance of notice under section 147(a) of the Income-tax Act, 1961 (in short referred to as "the Act"), is illegal and untenable and the reassessment made under the aforesaid provisions, should be declared void. For the purpose of this argument, we quote the following sections, viz., sections 3 and 8 of the Voluntary Disclosure of Income and Wealth Ac....

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....come-tax Act has been served upon such person and the return has not been furnished before the commencement of this Act; (ii) where any books of account, other documents, money, bullion, jewellery or other valuable articles or things belonging to the person making the declaration under sub-section (1) (hereafter in this section, in sections 4 to 13 and in the schedule referred to as the declarant) have been seized as a result of any search under section 132 of the Income-tax Act or under section 37A of the Wealth-tax Act, the income in respect of the previous year in which such search was made or any earlier previous year. (3) In addition to the amount of income-tax to be paid under sub-section (1), the declarant shall invest a sum eq....