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2024 (2) TMI 895 - SCH - Income TaxApplication for settlement of cases u/s 245C - disclosure of income - under valuation of stock - as decided by HC [2016 (8) TMI 1358 - ALLAHABAD HIGH COURT] ITSC in the case in hand warrants no interference as there is no contravention of any provision of statute and ITSC has not committed any manifest error so as to warrant interference in writ jurisdiction under Article 226 of the Constitution of India - HELD THAT:- We find that (i) the principles laid down by this Court in Ajmera Housing Corporation and another vs. Commissioner of Income Tax [2010 (8) TMI 35 - SUPREME COURT] have been correctly understood by the High Court; (ii) keeping in view the peculiar facts and circumstances of the cases in hand, the High Court has rightly affirmed the order(s) passed by the Settlement Commission. On re-appreciation of the facts of each case, we are satisfied that there was no deliberate attempt on the part of the respondent-assessees to suppress or conceal any material information. There was faithful compliance of Section 245-C as interpreted by this Court in Ajmera Housing Corporation case (supra). No case to interfere with the impugned judgment(s) is made out. The civil appeals are, accordingly, dismissed.
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