The Finance Act, 2021, inserted S. 245C(5) to bar settlement applications retrospectively from 01.02.2021, but the Act itself was notified only on 01.04.2021. The assessee filed its application on 18.03.2021. The High Court held that the subsequent retrospective amendment could not invalidate the application, which was valid when filed. The assessee had acquired a vested right, and the statutory prohibition that an application ‘shall be made’ could not nullify an act that was already completed. The Court further held that a CBDT notification dated 28.09.2021 was invalid to the extent it imposed an additional condition that the assessee must have been eligible to file on 31.01.2021. Such a condition was beyond the Board’s powers under Section 119, as a circular can relax the law but cannot impose a burden on the assessee not prescribed in the Act. (AY. 2014-15 to 2020-21)