Assessee filed applications before Settlement Commission for settlement of his income tax matters for assessment years 2014-15 to 2020-21. Settlement Commission treated application as invalid on ground that requisite conditions for filing settlement application under section 245C read with Finance Act, 2021, press release dated 7-9-2021 and CBDT’s order under section 119(2)(b), dated 28-9-2021 had prima facie not been fulfilled. On writ the Court held that  sub-section (5) of section 245C was not to make an application already filed after 1-2-2021 as invalid but it should be read as no application shall be made after 1-2-2021 once assent of President of India had been received, and any application made by assessee before grant of assent would not be hit by sub-section (5) of section 245C. The Settlement Commission was abolished by Finance Act, 2021 which was notified on 01-04-2021 and an Interim Board was constituted to deal with pending applications. Since assessee filed application before Settlement Commission, on 17-3-2021 i.e., prior to date when assent of President of India had been received for Finance Act, 2021, application was to  restored to file of Settlement Commission and Interim Board was directed to consider said application. The Finance Act, 2021 ((2021) 432 ITR (St.) 52).

.(AY. 2014-15 to 2020-21)