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    <title>2023 (12) TMI 1451 - KERALA HIGH COURT</title>
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    <description>Applications filed between 01.02.2021 and 31.03.2021 under the settlement scheme could not be rejected merely because no case was pending on 31.01.2021. The amended cutoff in Section 245C(5) of the Income-tax Act, 1961 was read down as not operating retrospectively to defeat applications filed during the interim period. The rejection orders and the circular treating such applications as ineligible were therefore inconsistent with that interpretation and were set aside; the applications were to be treated as pending.</description>
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      <description>Applications filed between 01.02.2021 and 31.03.2021 under the settlement scheme could not be rejected merely because no case was pending on 31.01.2021. The amended cutoff in Section 245C(5) of the Income-tax Act, 1961 was read down as not operating retrospectively to defeat applications filed during the interim period. The rejection orders and the circular treating such applications as ineligible were therefore inconsistent with that interpretation and were set aside; the applications were to be treated as pending.</description>
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