CBDT's additional eligibility condition for settlement applications ruled ultra vires Section 119(2)(b) powers

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....HC held that CBDT's order imposing additional eligibility condition requiring assessees to satisfy requirements as on 31.03.2021 was ultra vires Section 119(2)(b) powers. Court ruled that assessees receiving notices under Sections 153A/153C between 31.03.2021 and 30.09.2021 could maintain settlement applications before Interim Board for Settlement if filed by 30.09.2021. Single Judge's interpretation that search proceedings under Section 132 fall within 'case' definition was set aside. Revenue's writ appeals allowed partially. Court directed Interim Board to consider on merits settlement applications filed by assessees who received post-31.03.2021 notices, provided applications were submitted before 30.09.2021 deadline.....