TaxTMI 
TaxTMI 
2024 (9) TMI 293
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....or Mr. Ramamurthy. S. For the Respondent : Dr. B. Ramaswamy Sr. Standing Counsel ORDER This writ petition is filed challenging the impugned order dated 30.06.2023 of the respondent, whereby the respondent has rejected the compounding application filed by the petitioner on the ground that the application was filed beyond the period of limitation of 36 months, as stated in Para 7(ii) of the CBDT ....
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....Mad). The learned counsel therefore prays for quashing of the impugned order. 3. Per contra, Dr.B.Ramaswamy, learned senior standing counsel appearing for the Revenue, would fairly submit that this Court by virtue of the aforesaid judgment had struck down clause 7(ii) of the circular holding that it is beyond the scope of the Act. He would however submit that previously it was 12 months, but now ....
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....contrary to the object of the provisions. The explanation, which empowers the CBDT to issue circular, is only for the purpose of implementation of the provisions of the Act with regard to compounding of offences and not for the purpose of fixing a time limit for filing the application for compounding of offences and therefore, the same is contrary to the provisions of the Act and hence, it is not ....