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 the inclusion of the balance receipt of the minimum guarantee amount. By declaring the ...