Tax offense compounding timelines in guidelines invalid, exceeded statutory provisions. Fresh consideration ordered.

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....The High Court held that the Central Board of Direct Tax's Compounding Guidelines dated 16 September 2022, which rejected the application for compounding u/s 279(2) on the basis of a time frame, were invalid. Section 279(2) does not prescribe any timelines for filing an application for compounding, and the Guidelines exceeded the statutory provision by imposing a condition not contemplated by the Act. The Court set aside the order rejecting the compounding application and remanded the matter to the Chief Commissioner of Income Tax (TDS) for fresh consideration, bearing in mind the observations made by the Court.....