2021 (4) TMI 544

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.... of 2020 - -<br>Income Tax<br>THE HONOURABLE DR. JUSTICE ANITA SUMANTH For Petitioner: Mr.N.V.Balaji For Respondents: Mrs.Hema Muralikrishnana, Senior Standing Counsel ORDER The petitioner challenges an order of the Settlement Commission (SC)/Commissioner dated 15.05.2019 passed under Section 245D(2C) of the Income Tax Act, 1961 (in short Act) wherein the SC did not permit the petition....

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....ng of assessments for assessment years (AY) 2011-12, 2014-15 and 2015-16 under Section 147 of the Act. The petitioner filed a settlement application under Section 245 C of the Act and an order of admission passed under Section 245D(1) on 23.05.2019. After exchange of reports by the Commissioner of Income Tax and reply by the petitioner, the matter was posted for hearing in terms of Section 245D(2C....

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.... of income at the stage 245D(2C) would be beyond the scope of what that provision envisaged. The decision has been confirmed by the Division Bench on 04.09.2020 in W.A.No.581 of 2020. No serious contest is laid to this position by the revenue. 6. However, revenue points out that the petitioner has been lethargic in approaching this Court and there are laches on its part insofar as the writ peti....