Any disclosure made subsequent to seizure of incriminating material cannot be called voluntary

Merely because assessee cooperated in deciphering the seized documents would not mean that the revenue authorities could not have deciphered the same without voluntary assistance of assessee : High Court of Bombay.

Shardadevi P. Jhunjhunwala Vs. CIT, W. P. No. 428 of 1996, September 14, 2009

Gist of decision :

When the disclosure is made subsequently to the seizure of incriminating material, the disclosure is made because of adve

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