Review plea on Section 245C(5) interpretation, Settlement Commission abolition and Interim Board scope dismissed for delay

SC dismissed the review petition challenging its earlier interpretation of Section 245C(5) of the Income Tax Act, 1961, concerning abolition of the Income Tax Settlement Commission and the scope of the Interim Board. The applicant sought reconsideration of the reading down of the retrospective cut-off date and the treatment of applications filed between 01.02.2021 and 31.03.2021 as pending before the Interim Board. SC held that no error apparent on the face of the record or any substantive ground for review was made out and dismissed the review petition both for 387 days' delay and on merits.

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The Supreme Court addressed a Review Petition accompanied by an application seeking oral hearing in open court. The Court first rejected the application for oral hearing. It then noted a "gross delay of 387 days in filing the Review Petition," treating this as a significant procedural defect. After examining the Review Petition, the impugned order, and the annexed papers, the Court concluded that there was no "error apparent on the face of the record" and no substantive merit that would justify reconsideration. Accordingly, the Review Petition was dismissed both on the ground of inordinate delay and on merits. Any pending interlocutory applications were ordered to stand disposed of.

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