Section 519 — Power to tender immunity from prosecution

(1) The Central Government may, if it is of the opinion that with a view to
obtaining the evidence of any person appearing to have been directly or
indirectly concerned in or privy to the concealment of income or to the evasion of
payment of tax on income it is necessary or expedient so to do, for reasons to be
recorded in writing, tender to such person,—
( a) immunity from prosecution for any offence under this Act or under the
Bharatiya Nyaya Sanhita, 2023 (45 of 2023), or under any other Central
Act in force; and
( b) from imposition of any penalty under this Act on condition of his mak-
ing a full and true disclosure of the whole circumstances relating to the
concealment of income or evasion of payment of tax on income.
(2) A tender of immunity made to, and accepted by, the person concerned, shall, to
the extent to which the immunity extends, render him immune from prosecution
for any offence in respect of which the tender was made, or from the imposition of
any penalty under this Act.
(3) If it appears to the Central Government that any person to whom immunity has
been tendered under this section––
( a) has not complied with the conditions on which the tender was made; or
( b) is wilfully concealing anything; or
( c) is giving false evidence,
the Central Government may record a finding to that effect, and thereupon the
immunity shall be deemed to have been withdrawn.
(4) The person whose immunity has been withdrawn under sub-section (3) may be
tried for the offence in respect of which the tender of immunity was made or for
any other offence of which he appears to have been guilty in connection with the
same matter and shall also become liable to imposition of any penalty under this
Act to which he would otherwise have been liable.