Disclosure

At this stage, we deem it necessary to expound on the meaning of ‘disclosure’. As per P. Ramanatha Aiyar, ‘to disclose’ is to expose to view or knowledge, anything which before was secret, hidden or concealed. The word ‘disclosure’ means to reveal, unravel or bring to notice [CIT v. Bimal Kumar Damani, (2003) 261 ITR 87 (Cal)]. The word ‘true’ qualifies a fact or averment as correct, exact, actual, genuine or honest. The word ‘full’ means complete. Therefore, the meaning of ‘full and true disclosure’ is voluntary filing of a return of income an assessee earnestly believes to be true.

Hon’ble Justice Ujjal Bhuyan, M/s. Mangalam Publications, Kottayam v. Commissioner of Income Tax, Kottayam [Civil Appeal Nos. 8580-8582 of 2011].