Court held that only after the statutory amendment in 2015, restriction have been imposed. However, such restriction cannot be retrospectively made applicable to the application filed in 2012. The fate of the application is to be decided in the light of the provision as it stood in 2012. Subsequently, though the Explanation to Section 245A of the Act was amended, it cannot be made applicable retrospectively  therefore of the view that the 1^st respondent Settlement Commission has therefore correctly entertained the application of the 2^nd respondent. If the application was disposed then and there, there was no scope for confusion based on the plain reading of the provision. Accordingly directed  the Settlement Commission  to pass appropriate order on merits and bring a closure to the application filed by the 2^nd respondent under Chapter XIX-A of the Income Tax Act, 1961, within a period of six months from the date of receipt of a copy of this order. No cost. Consequently, connected Miscellaneous Petition is closed. (AY . 2008-09,2010-11,2011-12 & 2012-13)