JAMNAPRASAD KANHAIYALAL vs COMMISSIONER OF INCOME-TAX, M.P., BHOPAL

The Supreme Court held that Section 24 of the Finance (No. 2) Act, 1965 does not confer immunity from tax liability on persons other than the declarant. The Court clarified that the scheme was designed to protect only those who disclosed their own undisclosed income, and the legal fiction created by Section 24(3) is limited to the declarant. Consequently, the Income Tax Officer retains the authority under Section 68 of the Income Tax Act, 1961 to assess unexplained cash credits, affirming the Tribunal's decision to uphold the ITO's order.