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of Settlement Application under Section 245C - DGIT jurisdiction to issue the SCN - While the DGIT is deemed to be an 'Income Tax Authority' for the purposes of the Act, by virtue of Section 116, the ITSC is a statutory body created under Section 245B of the Act. It is rather unfortunate that a high ranking official as that of DGIT, was ignorant to understand the basic powers vested on him. - The DGIT had shockingly exceeded its powers and therefore, the impugned order cannot be sustained. - HC
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