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    <title>2026 (1) TMI 1387 - SC Order</title>
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    <description>Applications for settlement before the Interim Board were considered in light of whether the assessee had a live, unadjudicated notice under Sections 153A/153C when the application was filed. The text states that where Section 245C does not prescribe any prior cut-off date, an application filed while such proceedings are pending should be examined on merits. It also notes the view that a CBDT order under Section 119(2)(b) could not extend the filing period for settlement applications while denying the benefit to a class of assessees, and that the challenged clause in that order was treated as invalid. The applications filed on or before 30.09.2021 were directed to be considered on merits.</description>
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    <pubDate>Fri, 23 Jan 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=785631</link>
      <description>Applications for settlement before the Interim Board were considered in light of whether the assessee had a live, unadjudicated notice under Sections 153A/153C when the application was filed. The text states that where Section 245C does not prescribe any prior cut-off date, an application filed while such proceedings are pending should be examined on merits. It also notes the view that a CBDT order under Section 119(2)(b) could not extend the filing period for settlement applications while denying the benefit to a class of assessees, and that the challenged clause in that order was treated as invalid. The applications filed on or before 30.09.2021 were directed to be considered on merits.</description>
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      <pubDate>Fri, 23 Jan 2026 00:00:00 +0530</pubDate>
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