Scope of Sec.147 vis-a-vis declaration of income for advance tax.

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..... dvance tax collections during the financial year 1985-96 would be much higher than advance tax collections during any earlier financial year. 2. Fears have however been expressed that where a tax-payer declares for purposes of payment of advance tax during the current financial year a substantially higher income than that assessed for any earlier year the I.T.O. may suspect that income chargeabl .....

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..... ed in these decisions, the mere declaration for purposes of payment of advance tax, of much higher income than that assessed for any earlier year will not constitute a valid ground for re-opening the assessment for any earlier year. 4. Hence with a view to allaying such fears, it is hereby clarified that the mere fact that a taxpayer has declared for purposes of payment of advance tax during the .....

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..... assessed only in that year. Hence a taxpayer will not be able to claim that any part of the higher income declared by him for purposes of payment of advance tax should be set off against the income found to have been concealed by him any earlier year. In such cases the advisable course for the taxpayer will be to voluntarily and in good faith make a full and true disclosure of his concealed income .....

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