2025 (8) TMI 920

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....arakanath, A.S.G. Mr. Rupesh Kumar, Sr. Adv. Ms. Madhulika Upadhyay, AOR Mr. Udai Khanna, Adv. Mr. B K Satija, Adv. Mr. Ashok Kumar B, Adv. Mr. Rajat Vaishnaw, Adv. Mr. Mudit Bansal, Adv. Mr. S. Vijay Adithya, Adv. For the Respondent : Ms. Aishwarya Bhati, ASG Ms. Gargie Boss, Adv. Ms. Shagun Thakur, Adv. Mr. M. K. Maroria, AOR ORDER UPON hearing the counsel the Court made the following. ....

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....ion for settlement is rejected without providing for terms of settlement that Section 245HA of the 1961 Act will be applicable and the appellate proceedings will stand revived. The stand of the Revenue that the assessee must give up his right to contest the assessment order on merits, if the settlement application is rejected without providing for terms of settlement, is misconceived and ....