TMI Blog2023 (12) TMI 719X X X X Extracts X X X X X X X X Extracts X X X X ..... 245 C (1) - petitioner submitted that the entire tax liability along with interest has been discharged and no further amount is liable to be paid by the petitioner towards tax as well as interest - HELD THAT:- A mere perusal of the order impugned herein as well as the application made by the petitioner for third occasion, dated 10.3.2021, it is seen that the petitioner has clearly furnished the details with regard to the discharge of entire tax liability along with interest, however, the application came to be rejected, without stating as to why, the application is rejected and further, in the impugned order, there is not even a reference made with regard to the payment details made by the petitioner towards tax and interest and mechani ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n that tax on additional income and interest was not paid. The learned Senior Counsel further submitted that during the pendency of assessment proceedings, the Act was amended by the Finance Act, 2021 and the Settlement Commission was abolished, subsequently, pursuant to CBDT's order, dated 31.01.2021, Interim Board for Settlement II was constituted and the third application filed by the petitioner was allocated to first respondent/Interim Board for Settlement-II and thereafter, the petitioner's application was dealt with by the first respondent/Interim Board. The learned Senior Counsel submitted that when the petitioner submitted application before the first respondent/Interim Board for Settlement-II for third time, i.e. on 10.03.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 279) 14,578 1,00,82,261 (1,00,67,684) 2017-18 3,86,83,60,487 63,16,382 3,89,30,83,164 1,67,80,09,900 1,64,10,54,871 3,69,55,029 2018-19 60,64,90,110 - 60,64,90,110 23,54,65,990 15,86,58,635 7,68,07,355 TOTAL 4,16,41,52,594 4,50,16,868 4,22,77,27,870 1,94,22,54,365 1,85,38,06,696 8,74,47,668 2.1 The learned Senior Counsel for the petitioner submi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , their application has been rejected. 4. In reply, the learned Senior Counsel appearing for the petitioner submitted that the entire tax liability along with interest has been discharged and no further amount is liable to be paid by the petitioner towards tax as well as interest, and hence, 1st respondent may be directed to take the petitioner's application on record and dispose of the same in accordance with law, and in the event if any amount is still due, the application need not be considered. However, the learned counsel assured that no amount is due to be paid by the petitioner towards tax and interest. 5. Heard the submissions made by Mr.V.S.Jayakumar, learned Senior Counsel appearing for the petitioner and Mr.A.P.Srin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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