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The High Court held that the Income Tax Settlement Commission (ITSC) rightly restricted the applicability of interest u/s 234B on the total income disclosed in the Statement of Facts (SOF) up to the date of admission of the application u/s 245D(1). For considering the application, the ITSC must be satisfied that the applicant made a full and true disclosure regarding income and the settlement amount. After admission, the ITSC can call for reports, records, and undertake further inquiry under sub-sections (3) and (4), wherein the final amount payable could hypothetically be more than disclosed in the SOF. Following the Supreme Court's decision in Brij Lal, the interest liability u/s 234B cannot extend beyond the date of admission u/s 245D(1). Therefore, the ITSC correctly limited the interest liability to the date of admission, and the High Court dismissed the writ petition challenging this.
The High Court held that the Income Tax Settlement Commission (ITSC) rightly restricted the applicability of interest u/s 234B on the total income disclosed in the Statement of Facts (SOF) up to the date of admission of the application u/s 245D(1). For considering the application, the ITSC must be satisfied that the applicant made a full and true disclosure regarding income and the settlement amount. After admission, the ITSC can call for reports, records, and undertake further inquiry under sub-sections (3) and (4), wherein the final amount payable could hypothetically be more than disclosed in the SOF. Following the Supreme Court's decision in Brij Lal, the interest liability u/s 234B cannot extend beyond the date of admission u/s 245D(1). Therefore, the ITSC correctly limited the interest liability to the date of admission, and the High Court dismissed the writ petition challenging this.
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