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

Ravi Exports Pvt Ltd was given immunity under Section 519 of the Income-tax Act, 2025 for a concealment case. The Central Government later finds that Ravi's director wilfully concealed a material fact while giving evidence. What is the consequence?

Where the person wilfully conceals anything, gives false evidence or breaches the conditions, the Central Government may record a finding and the immunity is deemed withdrawn. He can then be tried for the offence and also becomes liable to the penalty that would otherwise have applied.

  1. AThe Central Government may record a finding to that effect and the immunity is deemed withdrawnCorrect
  2. BImmunity continues, but only a fine is levied
  3. CImmunity ends automatically after one year regardless of conduct
  4. DOnly the penalty immunity is withdrawn; the prosecution immunity remains

Explanation

Under Section 519(3), if the person has not complied with the conditions, is wilfully concealing anything or is giving false evidence, the Central Government may record a finding and the immunity is deemed withdrawn. Under 519(4) he may then be tried for the offence and becomes liable to the penalty he would otherwise have faced. So partial withdrawal is wrong.

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