Eligibility of settlement applications under amended settlement provision upheld for pre-assent filings; petition dismissed, question of law left open

Eligibility of settlement applications under the amended settlement provision turned on temporal applicability: applications filed before the presidential assent but after the Finance Bill's introduction and notices issued before 31.03.2021 are maintainable before the Interim Board for Settlement. The challenged proviso limiting applications after 01.04.2021 was read down so that applications filed between 01.02.2021 and 31.03.2021 cannot be declared invalid by virtue of the post-assent subsection. The Supreme Court declined to interfere with the High Court result and dismissed the special leave petition, leaving any open question of law undecided.

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"Delay condoned." Petition heard; counsel for petitioner addressed the Court. The bench stated it was "not inclined to interfere in the matter. However, the question of law, if any, shall remain open." Consequently, "The Special Leave Petition is, accordingly, dismissed." All pending applications, if any, "shall also stand disposed of." The order thus denies relief by declining to exercise discretionary jurisdiction under Special Leave, while expressly reserving any substantive or precedent-setting legal issue for future consideration. No substantive adjudication on merits or detailed legal reasoning is recorded beyond the non-interference stance and reservation of questions of law. Procedural posture: dismissal of the SLP with condonation of delay and disposal of ancillary applications.

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