Notices under sections 148/153 were issued to the assessees, who filed applications under section 245C(1) before 31-3-2021, i.e., after 1-2-2021 but prior to 1-4-2021. The Interim Board for Settlement treated such applications as invalid by relying upon the amended provisions introduced by the Finance Act, 2021. On writ petitions, the High Court held that though the amendment was stated to operate retrospectively from 1-2-2021, it was notified only on 1-4-2021 and, therefore, till 31-3-2021 there was no statutory prohibition against filing settlement applications. The Court read down para 4(i) of Circular dated 28-9-2021 and held that applications filed between 1-2-2021 and 31-3-2021 were to be treated as pending and eligible for consideration by the Interim Board. Accordingly, the orders of the Interim Board were set aside and matters were remanded for decision on merits. The Supreme Court dismissed the SLP and left the question of law open.(AY. 2010-11, 2013-14, 2016-17, 2017-18, 2019-20 , 2020-21)