The High Court held that:

• Relying on decision of Bombay High Court in Star Television News Ltd. vs. UOI & Ors. (2009) 317 ITR 66 (Bom.) (HC) (225 CTR 140) as approved by the Supreme Court in UOI v. Star Television News Ltd. ( 2015) 373 ITR 578 ( SC) if the proceedings were delayed due to reasons attributable to the applicants, the provision for abatement would apply but not otherwise
• ITSC to come to a conclusion whether assessee had deposited the tax or was short of doing it.
• ITSC to examine the fact that the assessee’s initial disclosure and further disclosures made nearly four years later were of additional sum in the light of Supreme Court’s judgement in the case of Ajmera Housing Corporation vCIT ( 2010)(326 ITR 642 ( SC)(SA. Nos 20442 of 2017dt. 18-04-2018)