Deemed pendency before the Interim Board under tax law upheld, leaving the writ appeal without merit.

Applications filed before the Interim Board for Settlement for assessment years 2014-15 to 2019-20 were treated as deemed pending under clause (iv) of the Explanation to Section 245A of the Income-tax Act, because binding Division Bench rulings covered applications arising between 01.02.2021 and 31.03.2021. That position had also been affirmed by the Supreme Court, and the appellant did not dispute the applicability of that authority. The writ appeal was further weakened by the admitted fact that the Single Judge's order had already been complied with, and the challenge was found to be without merit.

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Issues: Whether applications filed before the Interim Board for Settlement in respect of assessment years 2014-15 to 2019-20 could be treated as pending by virtue of clause (iv) of the Explanation to Section 245A of the Income-tax Act, 1961, and whether the writ appeal challenging the order granting relief to the assessee had merit.

Analysis: The controversy was covered by the binding Division Bench rulings holding that applications arising between 01.02.2021 and 31.03.2021 are to be treated as deemed pending for consideration by the Interim Board. The earlier view had also been affirmed by the Supreme Court, and the appellant did not dispute the applicability of that line of authority. The appeal also proceeded on the admitted basis that the order of the Single Judge had already been complied with.

Conclusion: The plea against deemed pendency was rejected and the writ appeal was held to be without merit.

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