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True and full disclosure" is the lifeline, satisfaction of which should remain to live in the mind of the Commission till the final order is passed on the other hand if the commission finds at any stage of the proceedings under section 245D that the applicant has not come before the commission with clean hands and by disclosing true and full income, it is empowered to reject the application. The factual findings rendered by the settlement Commission based on the report submitted by the revenue and in view of the conduct and inability of the assessee to satisfy the commission with regard to the deficiency in the disclosure of contents of pen drive and hard disc which contained accurate figures would certainly show that Commission was fully justified in holding against the assessee regarding full and true disclosure and when the settlement Commission was fully satisfied that there was suppression of materials and there was no full and true disclosure of income, even while hearing the matter and the stage of section 245 D(2C), it had ample power to rejecg the application at that stage itself

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Section 245D of the Income Tax Act, 1961 — Settlement of cases — "True and full disclosure" is the lifeline, satisfaction of which should remain to live in the mind of the Commission till the final order is passed on the other hand if the commission finds at any stage of the proceedings under section 245D that the applicant has not come before the commission with clean hands and by disclosing true and full income, it is empowered to reject the application. The factual findings rendered by the settlement Commission based on the report submitted by the revenue and in view of the conduct and inability of the assessee to satisfy the commission with regard to the deficiency in the disclosure of contents of pen drive and hard disc which contained accurate figures would certainly show that Commission was fully justified in holding against the assessee regarding full and true disclosure and when the settlement Commission was fully satisfied that there was suppression of materials and there was no full and true disclosure of income, even while hearing the matter and the stage of section 245 D(2C), it had ample power to rejecg the application at that stage itself — Abdul Rahim vs. ITSC [2018] 408 ITR 467 (Madras)

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