The appellants are a partnership firm.
The appellants disclosed thereby for the said Assessment Years en bloc an income of Rs.
The writ petition was summarily dismissed.
1 lakh being the value of miscellaneous assets, including furniture and fixtures.
The appellants made a request for review of this decision which on 30th December, 1975, was rejected.
A companyy of the appellants declaration in this behalf has been placed before us.
Their accounting year is the Samvat Year.
This appeal by special leave is preferred against that order.
During the search, which companytinued from time to time until the end of December 1975, cash, jewellery, diamonds and books of account were seized.
On 31st December, 1975, the appellants made a disclosure under Section 3 1 of the said Ordinance Act for the Assessment Years 1965 66 to 1975 76.
He added that the declaration ought to be filed under Section 14 1 .
The appellants made representations to the Central Board of Direct Taxes in furtherance of their desire to have the declaration under Section 3 1 accepted but on 20th June, 1980, the Board declined to interfere.
The appellants then filed a writ petition in the Delhi High Court impugning the decision to reject their declaration under Section 3.
On 31st December, 1975, which was the last date for filing of declarations under the said Ordinance Act, the appellants made a declaration, under protest, under the provisions of Section 14.
1.20 crores being the value of silver bars, silverware, diamonds, set jewellery and other ornaments Rs.
On 21st November, 1975 the 3rd respondent informed the appellants that since cash, jewellery, diamonds and books of accounts had been seized from the appellants before the declaration was filed, it was number in order under the terms of Section 3 2 ii .
On 28th October, 1975, a search on the premises of the appellants under Section 132 of the Income tax Act, 1961, was companyducted by the Commissioner of Income tax, Bombay City 1 the third respondent .
1.41 crores thus, Rs.
20 lakhs in cash and Rs.
The accounting year relevant to the Samvat Year 2031 and to the Assessment year 1976 77 ended on 3rd November, 1975.
The said Act was preceded by an Ordinance in the same terms, called the Voluntary Disclosure of Income and Wealth Ordinance, 1975, which had companye into force on that day.
P. Bharucha, J. We are companycerned in this appeal by special leave with the provisions of the Voluntary Disclosure of Income and Wealth Act, 1976 hereinafter called the said Act , which was deemed to have companye into force on 8th October, 1975.
