2024 (4) TMI 1320

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.... Order / Decisions)<br>Dated:- 25-4-2024<br>W. P. No. 2357 of 2024 and W. M. P. Nos. 2545 & 2551 of 2024 - -<br>Income Tax<br>HON&#39;BLE MR. JUSTICE SENTHILKUMAR RAMAMOORTHY For the Petitioner: Mr. R. Sivaraman. For the Respondents: Mr. A.N.R. Jayaprathap, Junior Standing Counsel. ORDER PER An order dated 27.12.2023 of the Interim Board for Settlement is challenged in this writ petiti....

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....er invited my attention to the impugned order and pointed out that the Interim Board for Settlement concluded that there is no deemed pendency as per clause (iv) of the Explanation to Section 245A of the Income Tax Act, 1961 (I-T Act). By referring to the Division Bench judgment of this Court, learned counsel pointed out that the Division Bench concluded that all applications in respect of cases a....

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....rtion of the judgment of the Division Bench of this Court reads as under:- "42. In the result, these writ petitions are partly allowed and are disposed off on the following terms:- (i) Section 245C(5) of the Income Tax Act, 1961 (as amended by the Finance Act, 2021) is read down by removing the retrospective last date of 1st date of February, 2021 as 31st day of March, 2021; ....

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.... scheme that may be framed by the Central Government as in respect of the other cases which arose prior to 31.01.2021;" 6. The said judgment is squarely applicable to the facts of this case since proceedings are deemed to have commenced prior to 31.03.2021. By following the judgment of the Division Bench, I set aside the impugned order insofar as the application for assessment year 2020-21 is c....