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    <title>2024 (8) TMI 1028 - BOMBAY HIGH COURT</title>
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    <description>An administrative condition narrowing statutory settlement eligibility beyond the parent enactment is impermissible. The Bombay High Court treated earlier jurisdictional rulings as controlling and held that the CBDT could not introduce, through delegated power, an additional requirement that the assessee be eligible to file a settlement application on 21 January 2021. On that basis, rejection of the settlement application on the ground that no proceedings were pending as on 31 January 2021 could not be sustained. The settlement order was set aside, and the application was directed to be considered on merits in accordance with law.</description>
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      <link>https://www.taxtmi.com/caselaws?id=757324</link>
      <description>An administrative condition narrowing statutory settlement eligibility beyond the parent enactment is impermissible. The Bombay High Court treated earlier jurisdictional rulings as controlling and held that the CBDT could not introduce, through delegated power, an additional requirement that the assessee be eligible to file a settlement application on 21 January 2021. On that basis, rejection of the settlement application on the ground that no proceedings were pending as on 31 January 2021 could not be sustained. The settlement order was set aside, and the application was directed to be considered on merits in accordance with law.</description>
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