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    <title>2023 (2) TMI 389 - ALLAHABAD HIGH COURT</title>
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    <description>A settlement application under the Income-tax Act must be based on a full and true disclosure of undisclosed income; inconsistent disclosures and material figures introduced only at rectification showed the requirement was not met, so the application was liable to be rejected. The Settlement Commission also acted beyond its limited jurisdiction by relying on receipts in the account of a non-applicant, treating already-assessed sums as part of the settlement, and using rectification to alter the original order in substance. It further could not waive statutory interest without a legal basis, as that power is confined by the statute and binding circulars. The impugned settlement orders were therefore set aside.</description>
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      <description>A settlement application under the Income-tax Act must be based on a full and true disclosure of undisclosed income; inconsistent disclosures and material figures introduced only at rectification showed the requirement was not met, so the application was liable to be rejected. The Settlement Commission also acted beyond its limited jurisdiction by relying on receipts in the account of a non-applicant, treating already-assessed sums as part of the settlement, and using rectification to alter the original order in substance. It further could not waive statutory interest without a legal basis, as that power is confined by the statute and binding circulars. The impugned settlement orders were therefore set aside.</description>
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