Standard Farms Pvt. Ltd. v. CIT (2025) 480 ITR 496 (SC). Editorial : CIT v. Standard Farms Pvt. Ltd. (2025) 483 ITR 621 (Delhi)(HC).

S. 245C : Settlement Commission-Settlement of cases-Conditions-Immunity from penalty and prosecution-High Court held that there was no foundation for finding of full and true disclosure by Settlement Commission-Matter remanded for reconsideration of grant of immunity-Review petition dismissed-SLP dismissed by Supreme Court with clarification that Settlement Commission shall decide matter independently in accordance with law and without being influenced by observations of High Court. [S. 245H, Art. 136]

On writ petitions filed by the Department challenging the order of the Settlement Commission granting immunity from penalty and prosecution, the High Court held that there was no foundation for the Commission’s satisfaction regarding full and true disclosure by the assessees. The matter was therefore remanded to the Settlement Commission for reconsideration of the question whether immunity under section 245H ought to be granted. The review petitions filed by the assessees were dismissed, the Court observing that neither the original order nor the final order of the Settlement Commission disclosed any reasons as to how it was satisfied about full and true disclosure or why the assessees were entitled to immunity. On SLP, the Supreme Court dismissed the petition and clarified that it had not interfered with the direction of remand and that the Settlement Commission shall examine the matter in accordance with law, without being influenced by the findings recorded by the High Court.

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