2023 (5) TMI 881 - HC - Income Tax

Settlement application u/s 245C(1) - whether there was no ‘case’ existing, thus the applications for settlement of case(s) u/s 245C was not maintainable? - HELD THAT:- A plain reading of Explanation (i) to Clause (b) of Section 245A of the Act clearly indicates that the proceedings in relation to assessment or reassessment or re-computation under Section 147 of the Act had not commenced in respect of the Assessment Years 2012-13, 2013-14 and 2014-15 and therefore, we find no infirmity with the decision of the Commission that the petitioner’s application under Section 245C of the Act in respect of the said assessment years, was not maintainable.