Settlement Applications Valid Pre-Amendment; Interim Board to Review, Actions by Assessing Officers Nullified.

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....Settlement applications filed between 01.02.2021 and 31.03.2021, prior to amendment of Section 245C(5) of the Act, are maintainable before the Interim Board for Settlement. Retrospective amendment cannot invalidate applications filed when no prohibitory statute existed. Petitioners had vested right to file applications before 31.03.2021 when amendment took effect. CBDT extending last date to 30.09.2021 for eligible cases as on 31.01.2021 cannot override non-existent Section 245C(5). Applications filed after 01.02.2021 but before 31.03.2021 cannot be invalid. Section 245C(5) rightly read down to apply from 01.04.2021 when assented. Petitions allowed, impugned orders set aside, applications deemed pending for Interim Board's consideration if otherwise eligible. Consequential actions by Assessing Officers quashed. Matter remanded to Interim Board for deciding applications on merits.....