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CA Final · Direct Tax Laws & International Taxation · Tax Planning, Tax Avoidance and Tax Evasion

Kiran Pvt Ltd, an Indian company, is in a tax dispute. The Central Government tendered immunity to Mr. Anil, who was indirectly concerned in concealment of income, on condition of full and true disclosure. Which statement about the scope of the immunity that may be tendered is correct?

The immunity can extend to prosecution for offences under the Income-tax Act, 2025, the Bharatiya Nyaya Sanhita, 2023 or any other Central Act in force, and also to imposition of penalty under the Act, provided the person makes a full and true disclosure of the circumstances.

  1. AIt covers only penalty under the Income-tax Act, 2025
  2. BIt covers only prosecution under the Income-tax Act, 2025
  3. CIt may cover prosecution for offences under the Act, the Bharatiya Nyaya Sanhita, 2023 or any other Central Act in force, and imposition of penalty under the ActCorrect
  4. DIt covers only offences under the Bharatiya Nyaya Sanhita, 2023, not penalty

Explanation

Section 519(1) allows immunity from prosecution for any offence under the Act, the Bharatiya Nyaya Sanhita, 2023 or any other Central Act in force, and from penalty under the Act, on condition of full and true disclosure. The other options narrow this scope.

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