2022 (10) TMI 663

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..... ke no difference as the said orders are patently illegal for the reason as the entire procedure as contemplated in Section 245-D(4) has been completely overlooked by Settlement Commission, as is evident from their own order and, therefore, the impugned orders are patently illegal and nullity in the eyes of law. HELD THAT:- While we agree with the impugned judgment dated 25.02.2015 that the orde .....

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..... om the date of first hearing. A reasoned order would be passed. Recording the aforesaid, the impugned judgment is partly set aside and the appeals are allowed in the aforesaid terms. We clarify that we have not made any observations or given any findings on the merits. - Civil Appeal No. …….of 2022 (@ SLP (C) No. 768 of 2016) with Civil Appeal No. ………. of 2022 (@SLP(C) No. 3783 of 2016), Civi .....

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..... Settlement Commission, being contrary to the mandate of Section 245-D(4) of the Income Tax Act 1961, we feel that the matter has to be remitted for fresh decision. Settlement Commission has been wound up, and the matters pending before the Settlement Commission are being adjudicated and decided by the Interim Board constituted under Section 245AA of the Income Tax Act, 1961. In view of .....

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