https://www.taxtmi.com/caselaws?id=779442 Pendency of a settlement application under Section 245F(2) meant the appellate proceedings were not finally extinguished; an order under Section 245D(4) had still to be passed. Only if the settlement application is rejected without terms of settlement does Section 245HA apply and the appellate proceedings revive. The Revenue's view that the assessee must abandon a merits challenge if settlement fails was rejected as misconceived. On that basis, the ITAT was held justified in condoning delay, setting aside the CIT(A) order, and restoring the first appeal; the special leave petition was dismissed. en-us Fri, 26 Sep 2025 00:00:00 +0530 Mon, 06 Oct 2025 09:10:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779442 Pendency of a settlement application under Section 245F(2) meant the appellate proceedings were not finally extinguished; an order under Section 245D(4) had still to be passed. Only if the settlement application is rejected without terms of settlement does Section 245HA apply and the appellate proceedings revive. The Revenue's view that the assessee must abandon a merits challenge if settlement fails was rejected as misconceived. On that basis, the ITAT was held justified in condoning delay, setting aside the CIT(A) order, and restoring the first appeal; the special leave petition was dismissed. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779442