https://www.taxtmi.com/caselaws?id=783691 The dominant issue was whether revised CBDT compounding Guidelines dated 17.10.2024 could be applied to compute compounding charges for an offence sought to be compounded under s. 279(2) of the Income-tax Act on an application filed on 05.03.2021 pursuant to earlier HC directions. The HC held that the Explanation to s. 279(6), though retrospective and functioning as a proviso requiring the Commissioner to act subject to Board instructions, did not authorise applying the 2024 Guidelines to an already pending compounding request; the revised regime could apply only upon an independent fresh application under the new Guidelines. Consequently, fixation of compounding fee under the 17.10.2024 Guidelines was set aside as unsustainable. en-us Tue, 16 Dec 2025 00:00:00 +0530 Mon, 11 May 2026 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783691 The dominant issue was whether revised CBDT compounding Guidelines dated 17.10.2024 could be applied to compute compounding charges for an offence sought to be compounded under s. 279(2) of the Income-tax Act on an application filed on 05.03.2021 pursuant to earlier HC directions. The HC held that the Explanation to s. 279(6), though retrospective and functioning as a proviso requiring the Commissioner to act subject to Board instructions, did not authorise applying the 2024 Guidelines to an already pending compounding request; the revised regime could apply only upon an independent fresh application under the new Guidelines. Consequently, fixation of compounding fee under the 17.10.2024 Guidelines was set aside as unsustainable. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783691