Assessees retain statutory right to apply under amended Sections 245A-M; settlement applications between Feb 1-Mar 31, 2021 valid

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....The HC allowed the writ petitions and held that assessees possess a statutory right to apply to the ITSC/Interim Board for settlement under the amended Sections 245A-M. The Court concluded the Finance Act, 2021, though retrospective, does not expressly or by necessary implication abrogate vested rights to file settlement applications between 01.02.2021 and 31.03.2021; the amendments merely rendered the ITSC inoperative and transferred pending matters to the Interim Board. The respondents' 28.09.2021 order is to be read down so that the cut-off of 31.01.2021 is read as 31.03.2021. The petitioners' settlement applications filed on 22.03.2021 are therefore validly pending for consideration by the Interim Board.....