1992 (11) TMI 278 - SC - Income Tax

Summary

Issues involved: Application for clarifications and directions by Union of India regarding the implementation of principles laid down in the main judgment.

Clarifications and Directions:
1. The Union of India sought clarifications and directions to address difficulties in applying the principles from the main judgment to cases beyond the specific petitioner's case.
2. The first aspect highlighted the challenges with pending similar petitions before the Supreme Court and various High Courts due to existing stay orders, hindering the immediate implementation of the judgment's directions.
3. The second aspect focused on pending matters before authorities that do not align with statutory limits, necessitating further guidance for proper implementation.
4. A clarification was made to adjust the time frame for cases pending before the Courts, stating that the period for affording an opportunity of being heard shall be calculated from the date of actual disposal of those matters.
5. Another clarification was provided for matters pending before authorities, stating that Form 37-I shall be considered filed as of the date of the main judgment for the completion of proceedings under section 269UD(1).
6. Certified copies of the main order and the clarification were to be provided to interested parties upon request.

This judgment addressed the practical challenges faced in implementing the main judgment's principles in cases beyond the specific petitioner, offering necessary clarifications and directions for pending petitions before the Courts and authorities to ensure a proper and consistent application of the law.