M/S. TANNA & MODI vs C.I.T. MUMBAI XXV .

The Supreme Court addressed the interpretation of the Voluntary Disclosure of Income Scheme, 1997, specifically Section 64(2) which allows for nullification of certificates if prior undisclosed search and seizure actions are revealed. The Court held that the Commissioner of Income Tax acted improperly by declaring the certificate null and void without adhering to principles of natural justice, as the firm was entitled to immunity under the scheme. The Court ultimately ruled in favor of the appellant, reinstating the validity of the certificate issued under the scheme.