Petitioner challenged the constitutional validity of amendment to Section 245A discontinuing operations of Settlement Commission w.e.f. 01-02-2021. Petitioner also challenged the validity of Circular No. P. No. 299/22/2021-Dir (Inv.III), dtd. 28-09-2021-The Court observed that neither there was any intent nor it was within purpose to do away with pending applications of cases from 01-02-2021 to 31-03-2021. The Court held that last date for filing of application in Section 245C(5) should be read as 31-03-2021 instead of 01-02-2021 and consequently the last date mentioned in the circular should also be read as 31-03-2021 and thus, the pending applications between 01-02-2021 to 31-03-2021 and as on 31-03-2021 should be deemed as pending applications for purposes of consideration by Interim Board. Followed,   CIT v. Shah Sadiq & Sons (1987) 31 Taxman 498 / 166 ITR 102 (SC) and UOI v. Tushar Ranjan Mohanty (1994) 5 SCC 2020. The Right to seek resolution through Settlement Commission conferred by Statute, within policy realm of State to make away remedy or benevolence. The Court also held that  the Court cannot substitute its opinion to abolition of Settlement Commission.