Dismissing the petition the Court held that the mere fact that an acknowledgement may have been issued in Form-4 by the CIT, CPC did not provide any immunity to the assessees if it was found that the declaration was contrary to S.  193 of the Finance Act, 2016 which begins with a non-obstante clause. Where the jurisdictional Principal Commissioner/Commissioner of Income Tax finds a declaration to be based on such misrepresentation or suppression of facts, he would not be precluded from holding the declaration itself to be void in terms of Section 193 of the FA, 2016. There is no provision as such in the IDS to afford the declarant a hearing prior to passing an order holding such declaration to be void for being in contravention of Section 193 of the FA, 2016.  (AY. 2011-2012, 2012-2013, 2016-2017)