Petitioner-company was subjected to search and seizure-Subsequently, notices under section 153A were issued to it. Petitioner filed an application under section 245C on 22-3-2021 along with an amount of Rs. 30.04 crore by way of tax and interest on income disclosed in said application as statutorily required. ITSC did not take any action on said application filed by petitioner. Meanwhile, Finance Act, 2021 was promulgated on 1-4-2021 which abolished ITSC and constituted an Interim Board for settlement of pending applications. Petitioner filed a writ petition contending that because of introduction of Finance Bill, 2021, respondents were not accepting applications for settlement under old dispensation. Court held that It cases of assessees commenced with issuance of notice under sections 153A, 153C and 142(1) in month of March, 2021, and settlement applications were made on 22-3-2021, pursuant to orders passed by High Court. Thus, applications were validly filed before ITSC which legally and factually existed, i.e., much before Finance Act, 2021 was promulgated on 1-4-2021. Court held that settlement applications of petitioners, even if filed after 1-2-2021, on 22-3-2021, shall be treated as pending applications to be considered by Interim Board. (AY. 2014-15 to 2020-21)
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