CIT v. Purshottamdas P. Patel (2019) 416 ITR 417/ 182 DTR 402 (Guj.)(HC)

S. 68(2) : Certificate issued under scheme final-Amount mentioned in certificate cannot be assessed as undisclosed income. [S. 158BC, 158BD]

Dismissing the appeal of the revenue the Court held that once the certificate under section 68(2) of the Finance Act, 1997 under the Voluntary Disclosure of Income Scheme had been issued by the Commissioner of Income-tax, it was not permissible for the Assessing Officer to go behind such certificate and he was required to accept it.  Accordingly the conclusions arrived at by the Tribunal were based upon concurrent findings recorded by it after appreciating the material on record. Nothing had been pointed out to indicate that the Tribunal had placed reliance upon any irrelevant material or that any relevant material had been ignored. The deletion of the additions was justified.