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Issues:
1. Reference of questions to the court beyond what was raised before the Tribunal. 2. Legality of redone assessments under the Voluntary Disclosure of Income and Wealth Act, 1976. 3. Classification of seized documents as income. 4. Rejection of thandal basis of transactions by the Tribunal. 5. Validity of the Voluntary Disclosure Scheme in ending liabilities. 6. Prosecution of petitions for reference under the Income-tax Act. Analysis: 1. The judgment addresses the issue of seeking reference of questions beyond those raised before the Tribunal. The court noted that the assessee sought reference of six questions, three of which were not proposed before the Tribunal. It was held that the assessee cannot seek reference of questions that go beyond what was raised before the Tribunal, thereby limiting the scope of reference. 2. Regarding the legality of redone assessments under the Voluntary Disclosure of Income and Wealth Act, 1976, the Tribunal's order was discussed. The assessee's business premises were searched, pronotes were seized, and revised returns were filed post the search. The Commissioner's order conditional upon proof of thandal business was highlighted. The Tribunal affirmed the appellate authority's decision that only a part of the income was related to thandal business, leading to a reduction in the assessed quantum. 3. The issue of seized documents being classified as income was examined. The Income-tax Officer rejected the evidence provided by the assessee regarding thandal business. The Tribunal accepted that only a part of the income was from thandal business, excluding it from the assessment. The pronotes were considered to represent unaccounted income, leading to the rejection of the assessee's claim that the Voluntary Disclosure Scheme ended all liabilities. 4. The rejection of the thandal basis of transactions by the Tribunal was discussed. The Income-tax Officer did not find the evidence provided by the assessee's witnesses credible. The appellate authority reduced the assessed quantum, considering some income derived from thandal business. However, the Tribunal upheld the appellate authority's decision, emphasizing that only a part of the income could be linked to thandal business. 5. The judgment also addressed the validity of the Voluntary Disclosure Scheme in ending liabilities. The court found the assessee's claim that the scheme ended all liabilities untenable. It was concluded that the assessee failed to prove that the entire assessed income was derived from thandal business, and the pronotes represented unaccounted income. 6. Lastly, the judgment expressed displeasure at the delayed prosecution of the petitions for reference under the Income-tax Act. The court highlighted the significant delay in complying with procedural requirements, leading to the petitions being numbered after almost 20 years. The petitions were deemed to have abated and were found to be without merit, emphasizing the importance of timely and diligent prosecution of legal matters.
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