Challenges to Finance Act 2021 changes on Income Tax Settlement Commission dismissed, questions of law kept open

SC considered challenges to the abolition of the Income Tax Settlement Commission and the restriction on filing applications before the Interim Board for Settlement introduced by the Finance Act, 2021. The petitions related to cases where only applications pending as of 01.02.2021 could be entertained by the Interim Board. Relying on an earlier order on the same issue, SC dismissed the special leave petitions. SC clarified that any substantial question of law arising from the controversy remains open for adjudication in an appropriate proceeding.

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The Supreme Court condoned the delay in filing the special leave petitions, thereby first addressing and allowing the procedural hurdle of limitation ("Delay condoned"). Relying on its earlier order dated 09.07.2024 in SLP (C) Diary No. 21948/2024, titled "Union of India and Ors. Vs. Velammal Chennai Educational Trust," the Court held that "these special leave petitions also stand dismissed." The dismissal is thus grounded in parity with the reasoning and outcome in the cited matter, without separate substantive adjudication on merits in this order. The Court expressly clarified that "The question of law, if any, shall remain open," indicating that no binding determination on any underlying legal issue was made. All pending applications were also disposed of.

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