https://www.taxtmi.com/caselaws?id=34624 The Bombay HC addressed the constitutional validity of arbitrary cut-off dates for settlement of income tax cases. The court held that harmonious interpretation of Section 245D(4A) and Section 245HA(1)(iv) would eliminate arbitrariness and preserve constitutional validity. The court ruled that applications abate under Section 245HA(1)(iv) only when disposal delays are attributable to the applicant, not the Settlement Commission. This interpretation prevents Section 245D(4A)(i) from becoming redundant and maintains Parliament's intention that the Settlement Commission must dispose of applications by specified dates. en-us Fri, 07 Aug 2009 00:00:00 +0530 Mon, 26 May 2025 10:38:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=34624 The Bombay HC addressed the constitutional validity of arbitrary cut-off dates for settlement of income tax cases. The court held that harmonious interpretation of Section 245D(4A) and Section 245HA(1)(iv) would eliminate arbitrariness and preserve constitutional validity. The court ruled that applications abate under Section 245HA(1)(iv) only when disposal delays are attributable to the applicant, not the Settlement Commission. This interpretation prevents Section 245D(4A)(i) from becoming redundant and maintains Parliament's intention that the Settlement Commission must dispose of applications by specified dates. Case-Laws Income Tax Fri, 07 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=34624