High Court Upholds CBDT Order on Settlement Applications Post-Commission Closure; No Discrimination Found u/s 119(2)(b.

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....Eligibility to file settlement application - benefit of extension of time to file application for settlement - Admittedly, in this case, application for settlement under Section 245C(1) of the Act was filed on 17th March, 2021 while the Settlement Commission had ceased to operate w.e.f. 1st February, 2021 in view of the aforesaid Finance Act, 2021 amending the provisions of the Act. - So far as challenged to the legality and validity of the order of the aforesaid order of Central Board of Direct Taxes dated 28th September, 2021, on the ground of discrimination in exercise of power under Section 119 (2) (b) of the Income Tax Act, 1961 is concerned, we hold the said order of the Board as constitutionally valid and legal and is perfectly within the power conferred upon it - HC....