Settlement application under amended section 245C must meet filing-date conditions and full disclosure requirements.

An application for settlement under Chapter XIX-A was held to be governed by the amended section 245C in force on the date of filing, because the settlement scheme is a conditional statutory concession and not a vested right. The amended provision required full and true disclosure of undisclosed income, the manner of derivation, and the additional tax payable, together with the applicable monetary threshold. As the application filed in 1989 did not satisfy those statutory conditions, it was not maintainable. The rejection of the settlement application was therefore upheld, and the writ appeal failed with costs.

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Issues: (i) Whether an application for settlement under section 245C had to satisfy the amended requirements in force on the date of filing, even though the assessment year related to an earlier period.

Analysis: The settlement mechanism under Chapter XIX-A was treated as a concessionary and machinery provision, not as a vested right of appeal. The amended section 245C, in force when the application was filed, required a full and true disclosure of undisclosed income, the manner of derivation, and the additional tax payable, and also imposed a monetary threshold. As the application filed in 1989 did not contain the mandated disclosure and particulars, it failed to satisfy the statutory conditions applicable on the date of filing. The authorities and the single judge were therefore right in holding that the earlier unamended provision could not govern the application.

Conclusion: The amended section 245C applied, and the settlement application was not maintainable.

Final Conclusion: The challenge to the rejection of the settlement application failed, and the writ appeal was dismissed with costs.

Ratio Decidendi: An application for settlement under section 245C is governed by the procedural and substantive conditions in force on the date of filing, because the provision confers only a conditional statutory concession and not a vested right.

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