Judgment :- R. JAYASIMHA BABU, J. Counsel contends that the amnesty scheme is available only to those who pay tax under that scheme. The scheme is one for "disclosure" and payment of tax is incidental. Disclosure of income which has the effect of reducing the loss is also a disclosure and that is what has been held by the Tribunal. We have not been shown anything in the scheme which makes it mandatory that the benefit of the scheme cannot be granted to an assessee who, as the result of the disclosure, is not obliged to make a payment. We do not see any infirmity in the order of the Tribunal. The petition (The petition was for an order directing reference of the following two questions : (1) Whether, in the light of the express requirement of payment of taxes vide Circular Nos. 439, 451 and other circulars of the Central Board of Direct Taxes, an assessee can whiten his black money with no penal action, even without paying any tax on the basis of the amnesty return ? (2) Whether the Commissioner of Income-tax (Appeals) and the Income-tax Appellate Tribunal are right in basing their judgment on their finding in other cases not before them though these other assessees are the mother-in-law of the assessee and a firm in which she is a partner ?) is dismissed.