Voluntary disclosure in all cases cannot absolve assessee from liability to pay penalty

Mr. Shanti Ramanand Sagar Vs. CIT (Bombay High Court)

In this case The Tribunal held that non-availability of the agreement does not mean that the nature of the transaction cannot be disclosed. If the assessee had declared a loss, he thwarted his tax liability for two years by not declaring the entire receipts in the assessment year 1977-78. The tribunal recorded a finding that even after the set-off of brought forward losses, the current year’s loss would have been converted into positive income with th

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