As per the case facts the revenue appealed against a High Court judgment that quashed a notice issued under the Income Tax Act seeking to re-open the respondent's assessment This ... re-opening was initiated after search proceedings uncovered relevant documents The question arose whether a declaration under a Voluntary Disclosure Scheme IDS could grant immunity from taxation to a non-declarant Finally the Supreme Court concluded that the High Court erred in holding that a declaration under the IDS could lead to immunity from taxation for a non-declarant The Court emphasized that the immunity conferred by certain provisions is limited and does not extend universally or to those proceeded against under other enactments Therefore the impugned judgment was set aside and the assessing officer was allowed to proceed with the re-assessment