Principles of estoppel do not apply to Income Tax proceedings
Income of the assessee must be taxed in the proper Assessment Year and within the limitation prescribed by the Income Tax Act, 1961. Further held that, the Revenue Department must decide matters on merit in accordance with law and not based on the admission or refusal made by the assessee. Remanded the matter back to the Assessing Officer (“AO”) with a direction to ignore the surrender made during the assessment proceedings and decide the matter on merit.