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Settlement applications filed by 30 September 2021 required only...
Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking consideration.
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Settlement applications filed by 30 September 2021 required only that the relevant assessment case be pending on the application date; no statutory requirement imposed eligibility by an earlier date. The Board's deadline-relaxation power could not add a prior-eligibility condition absent from the statutory scheme. Where live, unadjudicated notices under sections 153A or 143(2) existed, eligibility could not depend on delayed notice issuance, and differing treatment of years arising from the same search lacked a rational basis. Paragraph 4(i) and the corresponding press release were read down; rejected applications were restored for decision on merits, with consequential assessments subject to that decision. The constitutional challenge to section 245C(5) remained open.
Settlement applications filed by 30 September 2021 required only that the relevant assessment case be pending on the application date; no statutory requirement imposed eligibility by an earlier date. The Board's deadline-relaxation power could not add a prior-eligibility condition absent from the statutory scheme. Where live, unadjudicated notices under sections 153A or 143(2) existed, eligibility could not depend on delayed notice issuance, and differing treatment of years arising from the same search lacked a rational basis. Paragraph 4(i) and the corresponding press release were read down; rejected applications were restored for decision on merits, with consequential assessments subject to that decision. The constitutional challenge to section 245C(5) remained open.
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