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    <title>2020 (5) TMI 656 - MADRAS HIGH COURT</title>
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    <description>A settlement application under Section 245C of the Income-tax Act was maintainable where, on the filing date, a &quot;case&quot; was pending before the Assessing Officer under Section 245A(b) as then in force. The Court treated pendency of assessment proceedings as the ative condition and noted that the limitation period under Section 153 had not expired for the later assessment years. It also held that the 2015 amendment to Explanation (iv) to Section 245A could not operate retrospectively to invalidate an application filed in 2012. The prevailing statutory scheme and contemporaneous circulars supported assessing maintainability by the law applicable at the time of filing.</description>
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      <description>A settlement application under Section 245C of the Income-tax Act was maintainable where, on the filing date, a &quot;case&quot; was pending before the Assessing Officer under Section 245A(b) as then in force. The Court treated pendency of assessment proceedings as the ative condition and noted that the limitation period under Section 153 had not expired for the later assessment years. It also held that the 2015 amendment to Explanation (iv) to Section 245A could not operate retrospectively to invalidate an application filed in 2012. The prevailing statutory scheme and contemporaneous circulars supported assessing maintainability by the law applicable at the time of filing.</description>
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