In Brief
The Supreme Court examined whether the Income Tax authorities could reopen the assessment of a company that had received share premium and share capital from entities involved in an Income Declaration Scheme. The Court held that immunity under the Voluntary Disclosure Act is limited and cannot protect non-declarants from taxation. Even if one party to a transaction voluntarily discloses undisclosed income, the other party cannot claim immunity unless they themselves declare. The Court allowed the Revenue's appeal, permitting the Assessing Officer to complete reassessment where accommodation entries were suspected.
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