Timely section 273A amnesty application must be considered on merits despite later criminal proceedings

An application under the income-tax amnesty framework was filed before the scheme's last date, and the related criminal proceedings arose later. The assessee sought only consideration and disposal of the section 273A application in accordance with law, so the High Court's view that the request was belated or not voluntary could not stand. The orders were set aside, and the Commissioner was directed to consider and decide the application expeditiously under section 273A.

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Issues: Whether the assessee's application under section 273A of the Income-tax Act, 1961, made under the Amnesty Scheme, was required to be considered by the Commissioner and whether the High Court was right in refusing relief.

Analysis: The application had been filed before the last date under the Scheme and the criminal proceedings were lodged later. The assessee was seeking only consideration and disposal of the application under section 273A in accordance with law. In these circumstances, the High Court's view that the application was belated or not voluntary could not be sustained.

Conclusion: The High Court's orders were set aside and the Commissioner was directed to consider and dispose of the application expeditiously in accordance with section 273A.

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