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Issues:
Appeal against judgment of single Judge under Article 226 of the Constitution; Interpretation of press notifications issued by Ministry of Finance, Government of India regarding income disclosure and tax concessions; Assessment of disclosed income by Income-tax Department; Claim for deductions under press notifications; Entitlement to relief by way of mandamus and certiorari; Validity of assessment orders and penalties imposed. Analysis: The case involved an appeal against a single Judge's judgment under Article 226 of the Constitution, challenging the assessment of disclosed income by the Income-tax Department based on press notifications issued by the Ministry of Finance, Government of India. The appellants, two brothers owning various firms, disclosed concealed incomes totaling a specific amount under the press notification scheme. The Income-tax Department allowed deductions for intangible additions in previous years, resulting in a balance to be taxed. The petitioners sought relief through mandamus and certiorari, claiming that the Department should be bound by the press notifications for deductions. However, the High Court held that the press notifications lacked legal force and did not bind the Department to make deductions accordingly. The Court emphasized that the voluntary disclosures made by the petitioners were for the assessment years in question, precluding them from disputing the assessed income as not pertaining to those years. The Court further rejected the argument that the assessed amount should be subject to proceedings under Section 34 of the Income-tax Act, as the voluntary disclosures were made during the current assessment period and not subject to re-opening under Section 34. The appellants' failure to pay the demanded amounts led to penalties being imposed, which the Court found justified based on the circumstances. Additionally, the Court dismissed the writ petitions filed by the appellants challenging assessment orders for subsequent years, emphasizing that the deductions claimed were not valid under the press notifications and had already been considered in previous assessments. In conclusion, the High Court dismissed the special appeal and writ petitions, upholding the assessment orders and penalties imposed by the Income-tax Department. The Court found no legal basis for the appellants' claims for deductions under the press notifications and affirmed the assessments made for the disclosed incomes. Costs were awarded against the appellants, and the appeal and petitions were ultimately rejected.
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