https://www.taxtmi.com/caselaws?id=799530 Settlement application eligibility cannot be denied solely because the statutory notice was issued after 31 January 2021 where a live, unadjudicated notice under section 153A or section 143(2) existed when the application was filed by 30 September 2021. Section 245A(b) requires a pending assessment proceeding on the application date, while section 245C permits an application at any stage and does not require eligibility to arise by an earlier date. The CBDT eligibility condition is read down because departmental delay in issuing notices cannot defeat settlement access, and differential treatment of years from the same search lacks a reasonable classification under Article 14. Affected applications must be considered on merits by the Interim Board for Settlement. en-us Thu, 17 Sep 2026 00:00:00 +0530 Wed, 23 Sep 2026 08:48:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799530 Settlement application eligibility cannot be denied solely because the statutory notice was issued after 31 January 2021 where a live, unadjudicated notice under section 153A or section 143(2) existed when the application was filed by 30 September 2021. Section 245A(b) requires a pending assessment proceeding on the application date, while section 245C permits an application at any stage and does not require eligibility to arise by an earlier date. The CBDT eligibility condition is read down because departmental delay in issuing notices cannot defeat settlement access, and differential treatment of years from the same search lacks a reasonable classification under Article 14. Affected applications must be considered on merits by the Interim Board for Settlement. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799530