The assessee filed a settlement application on 15.03.2021. The Interim Board for Settlement rejected the application for the AY. 2020-21, relying on a CBDT order dated 28.09.2021 which imposed a new condition that the assessee must have been eligible to file the application as on 31.01.2021. As the assessee’s return for that year was filed after 31.01.2021, the Board held it to be ineligible. The High Court found that the CBDT, in its order under section 119, had exceeded its authority by creating an additional eligibility condition that was not present in the Income-tax Act, 1961. The Court declared this condition invalid. Accordingly, the rejection of the assessee’s application was set aside, and the matter was remitted to the Interim Board for consideration on its merits, with all other objections of the revenue being kept open. (AY. 2014-15 to 2020-21)