Sridhar Anand v. ITSC (2021) 435 ITR 435 / 280 Taxman 411 (Mad.)(HC)

S. 245C : Settlement Commission-Settlement of cases-No full and true disclosure of income-Rejection of application is held to be valid. [S. 245D, Art. 226]

Dismissing the petition the Court held that   the findings of the Settlement Commission were unambiguous and specific facts and circumstances were also relied on by the Settlement Commission to arrive at a decision regarding true and full disclosure by the assessee. The assessee was not able to establish that he had approached the Settlement Commission with clean hands and the element of true and full disclosure as contemplated under section 245C had not been established before the Settlement Commission and therefore, there was no perversity or infirmity as such in respect of the findings arrived. The rejection of the application for settlement of cases was justified.