Disclosure before criminal investigation wing cannot be treated as disclosure’ before assessing officer in assessment

RKR. Gold P. Ltd Vs ACIT (Madras High Court) The criminal investigation wing is separate and distinct from the assessment wing and disclosure made before one wing will not exonerate the petitioner from the requirement of making a ‘full and true disclosure’ before the assessing officer in assessment. In fact, the apparent difference in the communications addressed to the assessing authority on the one hand and the ITO (ICI) on the other, would itself illustrate the difference in the disclosures made before the two authorities. Records have been summoned and produced by the standing counsel,...