SEARCH & SEIZURE & SETTLEMENT COMMISSION

SEARCH & SEIZURE & SETTLEMENT COMMISSION
DIRECT TAX REFRESHER COURSE, 2017 SEARCH & SEIZURE & SETTLEMENT COMMISSION CA VIPIN K. GUJARATHI

DTRC, 2017 SEARCH & SEIZURE 10/06/2017 CA VIPIN K. GUJARATHI

AMENDMENTS BY FINANCE ACT 2017
New Explanation to Section 132(1) & 132A (1) inserted by the Finance Act 2017 w. e. f. 01/04/1962 & 01/10/1975 respectively. Explanation : For the removal of doubts, it is hereby declared that the reason to believe as recorded by the income-tax authority under this sub-section, shall not be disclosed to any person or any authority or the Appellate Tribunal. 10/06/2017 CA VIPIN K. GUJARATHI

Sec. 132 does not confer any arbitrary authority on the Revenue officers—Power must be exercised strictly in accordance with the law and only for the purpose for which the law authorizes its exercise. Seth Brothers 74 ITR 836 (SC) Vindhya Metal Corporation 224 ITR 614 (SC) UOI Vs Ajit Jain 280 ITR 280 (SC) 10/06/2017 CA VIPIN K. GUJARATHI

Warrant of authorization can be issued only if the conditions specified in section 132(1) (a) or (b) or (c) are complied with The assessee has right to file Writ Petition under Article 226 of the Constitution of India against the validity of the search action. However, for filing Writ Petition the assessee must know the reasons for search action. By inserting Explanation the assessee as well as any authority including Tribunal is denied the opportunity of knowing the reason. Under such circumstance filing of Writ petition is not possible 10/06/2017 CA VIPIN K. GUJARATHI

Insertion of section 132(9B) –Power of provisional attachment of the property during the course of search or within 60 days from execution of the last of the authorizations Power of Provisional Attachment are vested with the AO u/s 281B. By this amendment powers can be exercised by authorized officers during the search or within 60 days of end of search action 10/06/2017 CA VIPIN K. GUJARATHI

Insertion of section 132(9D) Power to make reference to Valuation Officer referred to in section 142A during or within 60 days from end of the search action who will submit report with in 60 days Object of amendment is to enable correct estimation & quantification of undisclosed income held in the form of investment or property. Assessee may be confronted during post search enquiries. 10/06/2017 CA VIPIN K. GUJARATHI

Amendment to section 153A & Section 153C of the I T Act Section 153A (1) (a) & (b) and Section 153C before amendment provided that where the search is initiated after 31st day of May 2003 the AO shall issue notice for the six assessment years immediately preceding assessment year relevant to the previous years in which the search is conducted and assess or reassess income of such six assessment years 10/06/2017 CA VIPIN K. GUJARATHI

Now the section 153(1)(a) and section 153A(1)(b) has been amended to include “Relevant Assessment Years” in addition to six assessment years. Relevant assessment Year/s mean beyond six years and not beyond 10 years. Therefore, now AO in respect of search conducted after 01/04/2017 can issue notice u/s 153A(a) for 10 assessment years subject to certain conditions. 10/06/2017 CA VIPIN K. GUJARATHI

Explanation 1 to section 153A defines the expression “Relevant Assessment Year” shall mean an assessment year preceding the assessment year relevant to the previous year in which the search is conducted or requisition is made which falls beyond six years but not later than ten assessment years from the end of assessment year relevant to the previous year in which the search is conducted 10/06/2017 CA VIPIN K. GUJARATHI

Fourth proviso to section 153A provides that AO shall not issue notice for the relevant assessment years unless the income, in the form of asset, which has escaped assessment amounts to or is likely to amount to 50 lakh rupee or more in the relevant A. Y. or in aggregate in the relevant Assessment Years This amendment is applicable for search initiated on or after 1st April 2017 10/06/2017 CA VIPIN K. GUJARATHI

Explanation 2 to section 153A has been inserted according to which the “asset” referred to in fourth proviso shall include immovable property being land or building or both, shares and securities, loans and advances and deposits in bank account. Any other asset can not be considered for computing limit of Rs. 50 Lakhs Consequential amendments have been made in section 153C. 10/06/2017 CA VIPIN K. GUJARATHI

Memorandum explaining amendments states that section 153A & 153C are amended as the existing provisions of clause (c) of the section 197 of the Finance Act 2016 treating the income or asset found as the income of the year in which notice u/s 142, 143 or 153A or 153C is deleted w. e. f. 1st June 2016 10/06/2017 CA VIPIN K. GUJARATHI

Amendment to sub-clause (c) to section 271AAB w. e. f Section 271AAB(1)(c) provided that penalty in case of undisclosed income of specified previous years was leviable at the rate of 30% of the undisclosed income if the case does not fall under sub-clause (a) or (b) of section 271AAB(1) of the Act. 10/06/2017 CA VIPIN K. GUJARATHI

Sub clause (c) of sub section (1) of section 271AAB has been amended to provide that the penalty shall be levied at the rate of 60% of the undisclosed income of the specified previous years if it is not covered by the provisions of clause (a) or (b) The amendment is w. e. f. 01/04/2017 10/06/2017 CA VIPIN K. GUJARATHI

TAXATION LAW (SECOND AMENDMENT) ACT 2016
Insertion of Sub-section (1A) of section 271AAB w. e. f. 15/12/2016. Sub clause (a) to section 271AAB (1A) provides that penalty u/s 271AAB (1A) in respect of search initiated after 15th December 2016 shall be 30% of undisclosed income of specified previous years if the assessee, fulfills the following three conditions: 10/06/2017 CA VIPIN K. GUJARATHI

Three Conditions of S 271AAB (1A): A) admits UDI in the course of search in the statement u/s 132(4), B) substantiates the manner of deriving UDI & pays tax together with interest and C) Furnishes the return before specified date Sub clause (b) provides that if the case is not covered by sub clause (a) the penalty shall be leviable 60% of undisclosed income of specified previous year 10/06/2017 CA VIPIN K. GUJARATHI

Section 273B provides that no penalty shall be levied if the assessee proves that for the failure there was a reasonable cause for said failure. However, section 273B has not been amended to include section 271AAB and therefore, it will be very difficult to argue the case of the ground of reasonable cause. 10/06/2017 CA VIPIN K. GUJARATHI

Amendment to section 153C of the I T Act w. e. f. 1st June 2015 Prior to amendment to section 153C the AO of the searched person was empowered to initiate proceedings u/s 153C in case of any person other than searched person only when the money bullion jewellery or other valuable article or books of accounts or documents belongs or belong to person other than searched person. 10/06/2017 CA VIPIN K. GUJARATHI

The Finance Act 2015 has amended section 153C w. e. f. 1st June 2015 which enables the AO of the searched person to initiate proceedings under scetion153C even if the books of accounts or documents do not belong to other person. The requirement is the documents “relate to” or “pertains to” such other person 10/06/2017 CA VIPIN K. GUJARATHI

any money, bullion, jewellery or other valuable article or thing, seized or requisitioned belongs to or any books of accounts or documents, seized or requisitioned pertains or pertain to any information contained therein, relates to The amendment has widened the scope of section 153C 10/06/2017 CA VIPIN K. GUJARATHI

EFFECT OF AMENDMENT TO SECTION 153C
Before amendment to S. 153C the requirement that the documents found during search should “belong” to such other person was a condition precedent and a jurisdictional issue. The non-satisfaction of the condition renders the entire proceedings null and void. Arpit Land Developers Pvt Ltd ITA No. 83 of 2014 (Bom) Vijaybhai Chandrani 333 ITR 436 (Guj) 10/06/2017 CA VIPIN K. GUJARATHI

Relates to, Refers to or Pertains to
Pepsi India Holdings Pvt. Ltd (Delhi) – Rebuttal of presumption u/s 132(4A) (i) & 292C (1)(i) documents belong to person from whose custody is found has explained the terms “relate to” or “refers to” A Registered Sale Deed belongs to the purchaser although relates to refers to Vendor Photo copies of the documents found in search action on A may relate to B but may not belong to B 10/06/2017 CA VIPIN K. GUJARATHI

SECTION 153C ISSUES Finding of photo copies with searched person does not mean that they belong to the other person holding originals Recording of satisfaction u/s 153C- Even if the AO of searched person & of the other person is the same, the proper satisfaction has to be recorded before assuming jurisdiction over other person CIT Vs M/s Mechmen (MP) Tanvir Collection Pvt Ltd Vs ACIT (Delhi) 10/06/2017 CA VIPIN K. GUJARATHI

Time of recording of satisfaction by AO of searched person
Time or at which stage AO of the searched person should record the satisfaction as to the documents belonging to other person was subject of controversy. Now the controversy is put to rest by the Supreme Court in the case of CIT Vs Calcutta Knitwears 362 ITR 673 held as follows: For the purpose of S. 158BD of the Act satisfaction note is sine quo non and must be prepared by AO before he transmit the record to other AO 10/06/2017 CA VIPIN K. GUJARATHI

Time of recording of satisfaction by AO of searched person
Satisfaction note could be prepared either (a) at the time or along with initiation of proceedings against the searched person u/s 158BC or (b) along with the assessment proceedings u/s 158BC or (c) immediately after assessment proceedings are completed. CBDT Circular 24/2015 Dt. 31st December 2015 accepted that the provisions of section 153C are substantially similar/pari materia to section 158BD Cit Vs Apna Organics 374 ITR 55 (Bombay) 10/06/2017 CA VIPIN K. GUJARATHI

Addition u/s 153A vis-à-vis absence of incriminating documents
Whether addition can be made under section 153A even if no document or material or evidence is found in the course of search action? Once search takes place u/s 132 the AO has to necessarily issue notices u/s 153A(a) for six preceding Assessment Year relevant to AY of search and assess or reassess income of each of six assessment years 10/06/2017 CA VIPIN K. GUJARATHI

The issue arises whether AO, even if no incriminating material is found, still require to assess or reassess income of all assessment years? Kabul Chawla 380 ITR 573 (Delhi) has held that no addition can be made in respect of an unabated assessment which has become final if no incriminating material is found during the search. The law has been explained as follows: 10/06/2017 CA VIPIN K. GUJARATHI

Once search takes place u/s 132 the AO will have to mandatorily issue notice to the assessee to file returns for six years Assessment or reassessment pending on the date of initiation of search shall abate and AO will have to pass fresh orders One assessment order for disclosed as well as undisclosed income for each of six assessment years 10/06/2017 CA VIPIN K. GUJARATHI

Addition u/s 153A vis-à-vis absence of incriminating documents?
Although the section 153A does not say that assessment should be strictly made on the basis of evidence found as a result of search or post search enquiries. However, the assessment can not be arbitrarily made. In absence of incriminating material the completed assessment can be reiterated & abated assessment can be made afresh 10/06/2017 CA VIPIN K. GUJARATHI

The word “assess” in S 153A is relatable to the abated proceedings and the word “reassess” to completed assessment proceedings Completed assessment can be interfered with by the AO only on the basis of incriminating material found in the course of search action 10/06/2017 CA VIPIN K. GUJARATHI

Kurele Paper Mills which refers to Kabul Chawla has been affirmed by Supreme Court by dismissing Revenue’s petition on 7th December 2015 Continental Warehousing Corporation 374 ITR 645 (Bombay) Saumya Construction Pvt. Ltd 387 ITR 0529(Gujarat) Salasar Stock Broking Ltd (Calcutta) Gurindersingh Bawa 386 ITR 483 (Bombay) 10/06/2017 CA VIPIN K. GUJARATHI

Judgment of Delhi HC –Dayawanti Gupta 390 ITR 496 was being interpreted to mean that addition can be made u/s 153A even without incriminating documents. Delhi High Court in the recent and longest decision –Meeta Gutgutia & Ors ITA 309/2017 delivered on 25th May 2017 analyzed judgments of all High Courts reaffirmed the judgment of Kabul Chawla and held that the no addition can be made in absence of incriminating documents. 10/06/2017 CA VIPIN K. GUJARATHI

Whether issue of notice u/s 143(2) is mandatory for assessment?
Whether it is mandatory to issue notice u/s 143(2) within the time limit provided in proviso to section 143(2) in assessment u/s 153A? Supreme Court in the case of Hotel Blue Moon has held that where the AO repudiates the return filed by assessee in response to notice u/s 158BC he must issue notice u/s 143(2)within the time prescribed in proviso to section 143(2) 10/06/2017 CA VIPIN K. GUJARATHI

The controversy arose because section 153A does not mandate the issue of notice u/s 143(2). It only requires issue of notice for six assessment years. Secondly, the judgment of Hotel Blue Moon was under chapter XIV-B block assessment with reference to section 158BC Now there are three High Court Judgments against the above propositions 10/06/2017 CA VIPIN K. GUJARATHI

Ashok Chaddha Vs ITO 337 ITR 399 (Delhi) CIT Vs Promy Kuriakose 386 ITR 597 (Kerala) Tarsem Singla Vs CIT 385 ITR 138 (P & H) A specific notice is required u/s 153A(1)(a) calling upon the person searched to file return and no further notice u/s 143(2) could be contemplated and judgment of Blue Moon was in the context of S. 158BC to which provisions of section 142, 143 (2) & (3), section 144 & 145 were specifically applicable, so far as may be. 10/06/2017 CA VIPIN K. GUJARATHI

Section 153C Issues As per proviso the Section 153C- Date of receiving documents by AO of other person is the date of search or making of requisition. Date of abetment of proceedings in the case of other person is the date on which the AO of such person receives documents/assets SSP Aviation Ltd 252 CTR 291 (Delhi) 10/06/2017 CA VIPIN K. GUJARATHI

Section 153C Issues Normally the documents are handed over by the AO of searched person to the AO of the other persons only after he realizes that the documents/assets belong to other person. This has the effect of block period being different in case of searched person and other persons. V K Fiscal Services Pvt Ltd ITA No 5460 to 5465 /Del/2012 R. L. Industries ITAT Delhi ITA No 567 & 568/Del/2011 10/06/2017 CA VIPIN K. GUJARATHI

Section 153C Issues Let us take a case that search is carried out in March The block period for the searched person will be AY to However the AO of the searched person hand over the documents or assets after 31st March Therefore, in case of other person the block period will be A. Y to 10/06/2017 CA VIPIN K. GUJARATHI

SETTLEMENT COMMISSION
10/06/2017 CA VIPIN K. GUJARATHI

A premier Alternative Dispute Resolution Body in India with the mandate to resolve tax dispute in respect of Income Tax and Wealth Tax Laws between two disputing parties – Income Tax Department on one side and Litigating tax payer on the other side 10/06/2017 CA VIPIN K. GUJARATHI

ITSC was set up in 1976 on the recommendations of Direct Tax Enquiry Committee set up under the Chairmanship of Justice K. N. Wanchoo popularly known as “Wanchoo Committee”. ITSC is an independent quasi-judicial authority. It is an attached office of the Department of Revenue 10/06/2017 CA VIPIN K. GUJARATHI

Settlement Commission comprises of Chairman and as many Vice-chairmen and other members as Central Government thinks fit. At present there are seven benches of settlement commissions. Delhi Bench is Principal Bench and other benches are known as additional benches. 10/06/2017 CA VIPIN K. GUJARATHI

SCOPE & POWER OF ITSC ITSC mechanism allows taxpayer to disclose additional income before it over and above what has been already been disclosed before Income Tax Authority. The applicant has to pay full amount of tax and interest on additional income disclosed before ITSC before filing application 10/06/2017 CA VIPIN K. GUJARATHI

SCOPE & POWER OF ITSC ITSC decides upon the admissibility of applications and carries out the process of settlement in time bound manner by giving opportunity to both the parties Object of Chapter XIX-A is not to give amnesty to tax evader from paying tax due but to see that protracted litigation is avoided and Revenue is collected earlier CIT Vs Anjum Ghaswala 252 ITR 1 (SC) CIT Vs Om Prakash Mittal 273 ITR 326 (SC) 10/06/2017 CA VIPIN K. GUJARATHI

WHEN ONE CAN APPROACH ITSC
An applicant can approach ITSC in respect of a “Case” if no assessment order is passed by concerned IT authority in respect of the assessment year/s and the statutory time limits for passing of assessment order for that assessment year has not lapsed. W. e. f. 01/06/2007 Definition of “Case” is further expanded to include such cases of search u/s 132 or requisition of books of accounts u/s 132A w. e. f. 1st June 2010 10/06/2017 CA VIPIN K. GUJARATHI

The Finance Act 2010 excluded the cases of reassessment, revision, set aside or cancelled assessment from the purview of the expression “Case”. The Finance Act 2015 w. e. f. 01/06/2015 included cases of reassessment. Similarly the Finance Act 2014 included cases of revision and set aside or cancelled assessment as a “Case”. 10/06/2017 CA VIPIN K. GUJARATHI

An applicant can approach ITSC in respect of proceedings which are pending. Proceedings are considered to be pending from the 1st day of the assessment year and it is not necessary that a return of income is filed or notice for scrutiny is issued before filing application. However, one can not approach ITSC once the assessment order is passed or time for passing the order has expired 10/06/2017 CA VIPIN K. GUJARATHI

APPLICATION TO ITSC U/S 245C
Application to ITSC is in Form 34B The application must contain a “Full and True” disclosure of his income which has not been disclosed before the AO. This is the most important criteria. The applicant must explain the manner in which such income has been derived. “Manner” of deriving undisclosed is one of the most important criteria. 10/06/2017 CA VIPIN K. GUJARATHI

Additional amount of income tax payable on such income must be paid on or before filing of application and such other particulars as may be prescribed The manner in which issues/disputes be settled by ITSC and the manner in which such application be disposed off must be stated in the application 10/06/2017 CA VIPIN K. GUJARATHI

Additional tax and interest thereon which would have been paid under the provisions of Act had the income disclosed in the application been declared before the AO on the date of application must be paid before the date of making application Every application shall be accompanied by fee of Rs. 500/-. 10/06/2017 CA VIPIN K. GUJARATHI

In cases where proceedings for assessment in Search Cases are initiated u/s 153A, 153B, 153C the additional amount of income tax payable on income disclosed in the application exceeds Rs 50 Lacs. It does not include interest. In any other case the additional amount of tax on the income disclosed in application exceeds Rs. 10 Lacs 10/06/2017 CA VIPIN K. GUJARATHI

w.e.f. 01/6/2011 new category of applicant “Specified Persons” has been added for the purpose of additional tax payable in case the applicant is related to person who is searched or requisition of books is made and proceedings under section 153A, 153B, 153C are initiated against such person. In such case additional income tax payable shall be Rs. 10 Lakhs. 10/06/2017 CA VIPIN K. GUJARATHI

SEC 245D PROCEDURE ON RECEIPT OF APPLICATION
Section 245D of the I T Act set out the procedure which is to be adopted by ITSC on receipt of an application u/s 245C On receipt of application u/s 245C the ITSC shall within 7 days from the date of receipt of application shall issue a notice to the applicant requiring him to explain as to why the application made by him be allowed to be proceeded with ITSC within a period of 14 days from the date of application by order in writing, reject the application or allow the application to be proceeded 10/06/2017 CA VIPIN K. GUJARATHI

ITSC can reject the application if the applicant does not satisfy the essential conditions mentioned in section 245C A copy of the application is to be sent to IT Authority on the date of application failing which it may be rejected. An applicant can not withdraw the application after filing before ITSC Section 245C(3) 10/06/2017 CA VIPIN K. GUJARATHI

An application can be rejected by Commission during the course of proceedings u/s 245D(1) within 14 days of filing of application As per proviso to section 245D(1) if the application is not rejected within 14 days it is deemed to have been admitted Application can be rejected if applicant does not satisfy the essential condition mentioned in section 245C 10/06/2017 CA VIPIN K. GUJARATHI

On receipt of application Commission shall issue the notice within seven days to the applicant requiring him to explain as to why the application made by him allowed to proceeded with. On hearing the applicant Commission shall within a period of 14 days from the date of application by an order in writing reject or allow the application to be proceeded with 10/06/2017 CA VIPIN K. GUJARATHI

A copy of every order u/s 245D(1) shall be sent applicant and Pr. CIT or CIT Settlement Commission shall call for a report from Pr. CIT or CIT within 30 days of receipt of communication from Commission 10/06/2017 CA VIPIN K. GUJARATHI

Where a Report of Pr. CIT or CIT called for u/s 245D(2B) has been furnished the Commission may on the basis of the Report and after giving an opportunity of hearing to both sides, within a period of 15 days by an order under s. 245D(2C) in writing, declare the application as valid or invalid and send the copy of the same to the applicant and Pr. CIT or CIT 10/06/2017 CA VIPIN K. GUJARATHI

Section 245D(3) –Commission in respect of an application which has not been declared as invalid may call for the records from PR. CIT and after examination of such records if Commission is of the opinion that any further inquiry or investigation may direct the PR. CIT or CIT to furnish the report to be furnished within period of 90 days 10/06/2017 CA VIPIN K. GUJARATHI

Settlement Commission after examination of the records and the Report of the Commissioner, if any, received under sub-section (2B) or Sub-Section (3) and after giving an opportunity to the applicant as also to Commissioner may pass such order in accordance with the provisions of the Act on the matters covered by the applicant and any other matter relating to case not covered by the applicant but referred to in the report of the commissioner 10/06/2017 CA VIPIN K. GUJARATHI

Order u/s 245D(4) must be passed in 18 months from the date of application. Section 245(6) every order passed u/s 245D(4) is to provide for the terms of settlement including any demand by way of tax, penalty or interest, the manner in which any sum due under the settlement is to be paid and all other matters to make the settlement effective. 10/06/2017 CA VIPIN K. GUJARATHI

In the Order u/s 245D(4) Commission is specifically to be provided that the settlement would be void if it was subsequently found by ITSC that it had been obtained by fraud or misrepresentation of facts. CIT Vs Om Prakash Mittal 273 ITR 326 (SC) 10/06/2017 CA VIPIN K. GUJARATHI

Whether disclosure made in application can be revised?
A scheme of Chapter XIX-A does not contemplate revision of the income so declared in the application. Revision would amount to fresh application not permitted under the scheme. True & Full Disclosure of income not declared before AO, “Manner of deriving undisclosed income and payment of tax on additional income are pre-requisite of a valid application. Ajmera Housing 326 ITR 642 (SC) 10/06/2017 CA VIPIN K. GUJARATHI

FULL & TRUE DISCLOSURE AND MANNER
The applicant is required to make “Full & True Disclosure” of additional income and the “Manner” of deriving the undisclosed income in the application which is a vital point for an application to be allowed to be proceeded with. The settlement application passes through several stages before the final order u/s 245D(4) is passed by ITSC 10/06/2017 CA VIPIN K. GUJARATHI

FULL & TRUE DISCLOSURE AND MANNER
The first stage is under section 245D(1) The next step is 245D(2C). Finally the order is passed u/s 245D(4) providing terms of settlement Order u/s 245D(1) & 245D(2C) are not final orders and they are subject to the order passed u/s 245D(4) Issue of “Full & True Disclosure” & “Manner” is open till final order u/s 245D(4) 10/06/2017 CA VIPIN K. GUJARATHI

EFFECT OF FILING APPLICATION TO ITSC
Once the application is filed before ITSC, the jurisdiction for I T & Wealth Tax purposes gets shifted to ITSC for assessment proceedings. The jurisdiction shifts not form the date of admission but from the date of submitting application. 10/06/2017 CA VIPIN K. GUJARATHI

CHALLENGE TO ITSC ORDER
The Order of ITSC can be challenged in court of law by filling a writ petition when Principles of natural justice are violated Mandatory procedural requirements of law were not complied with. Normally High Court does not go into the merits of the case unless order is perverse. 10/06/2017 CA VIPIN K. GUJARATHI

RECTIFICATION OF ORDER U/S 245D(4)
Whether the Final Order passed u/s 245D(4) can be rectified? Section 245D(6B) Finance Act 2011 permits rectification of order within six months from the date of order Order can be rectified on application by Pr. CIT or applicant. Application may be filed by CIT or applicant within 6 months from the receipt of application 10/06/2017 CA VIPIN K. GUJARATHI

APPLICATION TO ITSC –ONCE IN LIFE TIME OPPORTUNITY
Benefit of settlement application can be availed by taxpayer only once in life time As per section 245K(2) provides that where a person has made application on or after 1st June 2007 and if such application is allowed to be proceeded with u/s 245d(1) such person or any related person shall not be subsequently entitled to make an application An applicant whose application has been rejected u/s245D(1) can still file application for settlement. CIT Vs Bhaskar Picture Place 247 ITR 391 (SC) 10/06/2017 CA VIPIN K. GUJARATHI

BENEFITS OF SETTLEMENT COMMISSION
Department to get over long and continued litigation in complicated cases with doubtful revenue Time consuming litigation in regular appellate procedure is avoided by Department & assessee as well Application is processed in time bound manner in 18 months. 10/06/2017 CA VIPIN K. GUJARATHI

BENEFITS OF SETTLEMENT COMMISSION
If the disclosure of the applicant is “Full and True” benefit immunity from penalties and prosecution are available to the assessee Confidentiality of assessee’s disclosure is maintained as the same could be used only in the settlement Commission except as provided in section 245HA(3) of the Act. 10/06/2017 CA VIPIN K. GUJARATHI

Thank You CA Vipin K. Gujarathi Vipin Gujarathi & Associates
Poonam Plaza, Market Yard Road, Pune – Tel No. 020 – /9 10/06/2017 CA VIPIN K. GUJARATHI

SEARCH & SEIZURE & SETTLEMENT COMMISSION

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