Settlement Commission time-limit under later regime applies to post-01.06.2007 applications; earlier precedent cannot validate delayed orders.

Settlement applications filed after 01.06.2007 are governed by Section 245D(4A)(iii) of the Income-tax Act, and the time-limit in that regime must be applied on its own terms. A precedent dealing with applications filed before 01.06.2007 cannot be extended to later applications to validate a settlement order passed beyond the prescribed period. The text also notes that a grievance based on lack of opportunity failed because the matter had been argued at length and no jurisdictional infirmity was shown in the writ court's approach.

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Issues: Whether the Settlement Commission's order passed under the settlement provisions, after the time prescribed by Section 245D(4A)(iii), could be sustained and whether the decision in Star Television News Ltd. applied to an application filed after 01.06.2007.

Analysis: The application before the Settlement Commission was filed after 01.06.2007, so the governing provision was Section 245D(4A)(iii) of the Income-tax Act, 1961. The earlier Bombay High Court decision dealt with applications filed before 01.06.2007 and the cut-off under the then applicable provisions; it did not govern later applications. On the facts, the Settlement Commission passed its order beyond the statutory period. The Court also held that the grievance based on lack of opportunity could not succeed because the matter had been argued at length and no jurisdictional infirmity was shown in the writ court's approach.

Conclusion: The challenge to the writ court's decision failed. The Settlement Commission order was not saved by the cited precedent, and the writ appeal was dismissed, leaving the assessee's relief intact.

Final Conclusion: The legal effect of the decision is that settlement proceedings initiated after 01.06.2007 remain governed by the later time-limit regime, and a precedent confined to earlier applications cannot be extended to validate an order passed beyond that period.

Ratio Decidendi: A precedent concerning settlement applications filed before 01.06.2007 cannot be applied to applications filed thereafter, and the time-limit prescribed under Section 245D(4A)(iii) must be given effect according to its own statutory regime.

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