← All Phrases

“settlement application”

Settlement & AmnestySection 245CSection 245C247 judgments

The decision most relied on for settlement application is CIT v. CPR Capital Services Ltd. (331 ITR 483), cited in 29 judgments on BharatTax.

Leading authorities on settlement application

CIT v. CPR Capital Services Ltd.
331 ITR 483 · 2011 · High Court
29
citing judgments

If there is a change in the assessing officer, a new notice under section 143(2) should be issued, especially after a settlement application is filed or jurisdiction is transferred.

Star Television News Limited v. UOI & Others
317 ITR 66 · 2009 · High Court
22
citing judgments

The Settlement Commission must hear applications where delay in disposal before March 31, 2008, is not attributable to the applicant. Section 245HA(1)(iv) is arbitrary and unreasonable if an applicant faces hardship due to the Settlement Commission's inability to dispose of applications by a specified date.

Nanji Enterprise Ltd. v. DCIT
84 Taxmann.com 155 · 2017 · High Court
15
citing judgments

Income offered to tax under a settlement application with the Income Tax Settlement Commission cannot be taxed again in the hands of the assessee, as the settlement order by its statutory scheme is final.

Dolat Investments Ltd. v. DCIT
38 SOT 123 · 2010 · ITAT
13
citing judgments

Confidential information disclosed to the Settlement Commission cannot be used by the Assessing Officer to make additions if the settlement application is not admitted under section 245D(1).

Ram Jethmalani v. Union of India
219 ITR 618 · 1996 · Supreme Court
12
citing judgments

Penalty proceedings do not fall within the ambit of Section 245E of the Income-tax Act, and the Settlement Commission exceeds its jurisdiction if it drops penalty proceedings while deciding a settlement application.

Omaxe Ltd. v. ACIT
254 CTR 370 · 2012 · High Court
11
citing judgments

Once an application is admitted by the Settlement Commission, it has exclusive jurisdiction over the assessee's case until a final order is passed, precluding the Assessing Officer and Commissioner (Appeals) from invoking reassessment provisions.

Komalkant Faikirchand Sharma v. DCIT
108 Taxmann.com 50 · High Court
10
citing judgments

Once an application for settlement is made under Section 245C(1) and accepted by the Income Tax Settlement Commission (ITSC), and a final order is passed under Section 245D(4), the Assessing Officer loses jurisdiction to reopen the assessment. An order under Section 245D(4) is distinct from a regular assessment under Sections 143(1), 143(3), or 144.

Gupta Perfumers (P.) Ltd. v. ITSC
348 ITR 86 · 2012 · High Court
10
citing judgments

Seized papers referred to in a settlement application, even if they belong to third persons, can be used and utilized against those third persons.

Judgments citing settlement application

Indu Bansal, Karnal vs. DCIT, Central Circle, Karnal

In the result, the addition of Rs

ITA 2863/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh[Assessment Year: 2017-18] Smt. Indu Bansal, Dcit, House No. L-506, Model Central Circle, Town, Karnal, Haryana- Vs Karnal. 132001. Pan- Ahopb3289R Assessee Revenue Assessee By Shri Ved Jain, Adv. & Shri Aman Garg, Ca Revenue By Shri Shravan Kumar Cit(Dr)

Section 132(4)Section 142(1)Section 143(3)Section 153CSection 69

details with regard to deposit of cash in the bank accounts and payment of cash to appellant were also disclosed. 15. That the settlement application of Sh. Sanjay Bansal has been duly considered by the ITSC at para 13.7, after due verification by the AO and after due consideration ... regard to deposit of cash in the bank accounts and payment of cash to assessee were also disclosed. It was further explained that the settlement application of Shri Sanjay Bansal was duly considered by the ITSC at para 13.7, which after due verification by the AO and after due consideration

Sh. Rakesh Soni, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result, appeal of the assessee is allowed

ITA 1292/JPR/2024[2017-18]Status: DisposedITAT Jaipur15 Sept 2025AY 2017-18
For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(4)Section 250Section 68Section 69

Bullion, proprietary concern of his 4 Sh. Rakesh Soni, Sikar. son Sh. Rakesh Soni during demonetization period. The relevant para 7 of the settlement application is reproduced as under:- “The applicant during the demonetization period from 09.11.2016 to 19.12.2016 accepted old demonetized currency from various persons against sale of jewellery ... over the oral statement. 2. It is stated that Sh. Ram Sh. Ram Kumar Soni in the There is no own Kumar Soni misused settlement application has explanation or assessee’s bank account categorically admitted that he evidence from the for rotation of utilized the bank account of assessee regarding

Hans Raj Memorial Educational Society, Jalandhar vs. Deputy Commissioner of Income Tax Central Circle-1, Jalandhar

The appeal stand allowed for statistical purposes

ITA 62/ASR/2025[2025-26]Status: DisposedITAT Amritsar28 Aug 2025AY 2025-26

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं. / Ita No. 62/Asr/2025 Hans Raj Memorial Educational Society Dcit बनाम/ Model Town Road, Central Circle-1 Vs. Jalandhar. Jalandhar "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaath-3891-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Rohit Kapoor (Advocate) & Shri V.S. Aggarwal (Itp) – Ld. Ars ""थ"कीओरसे/Respondent By : Shri Jivandeep Singh Kahlon (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 03-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 28-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aggrieved By Rejection Of An Application Seeking Approval U/S 10(23C)(Iii) Vide Order Dated 12-12-2024 Of Ld. Commissioner Of Income Tax (Exemption), Chandigarh, [Cit(E)], The Assessee Is In Further Appeal Before Us. 2. The Ld. Ar Advanced Arguments & Drew Attention To Settlement Arrived At By Assessee-Group Before Hon’Ble Income Tax Settlement Commission (Interim Board) (In Short Itsc). On The Basis Of These Documents, Ld. Ar Contended That The Assessee Would Be Eligible To Lay Claim On Impugned Deduction. The Ld. Cit-Dr Also Advanced

For Appellant: Shri Rohit Kapoor (Advocate) & Shri V.SFor Respondent: Shri Jivandeep Singh Kahlon (CIT) – Ld. DR
Section 10Section 245Section 245D(4)

from ADIT report which are flowing only from the seized documents pertaining to period prior to 25-09-2019 which period stood covered in settlement application. The order so passed by Hon’ble ITSC would be conclusive in terms of provisions of Sec.245-I of the Act. It could also

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3357/CHNY/2024[2020]Status: DisposedITAT Chennai14 Aug 2025

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

relied on by the assessee are not applicable to the facts of its case. ix. In fact, M/s Chettinad Products Private Limited have filed settlement application for the A.Ys. from 2015-16 to 2020-21 admitting the said amount of cash received from the assessee

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3355/CHNY/2024[2018]Status: DisposedITAT Chennai14 Aug 2025
For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

relied on by the assessee are not applicable to the facts of its case. ix. In fact, M/s Chettinad Products Private Limited have filed settlement application for the A.Ys. from 2015-16 to 2020-21 admitting the said amount of cash received from the assessee

Assisstant Commissioner of Income Tax, Chennai vs. Bannariamman Educational Trust, Coimbatore

ITA 3353/CHNY/2024[2015]Status: DisposedITAT Chennai14 Aug 2025

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

relied on by the assessee are not applicable to the facts of its case. ix. In fact, M/s Chettinad Products Private Limited have filed settlement application for the A.Ys. from 2015-16 to 2020-21 admitting the said amount of cash received from the assessee

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3314/CHNY/2024[2021-22]Status: DisposedITAT Chennai14 Aug 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

relied on by the assessee are not applicable to the facts of its case. ix. In fact, M/s Chettinad Products Private Limited have filed settlement application for the A.Ys. from 2015-16 to 2020-21 admitting the said amount of cash received from the assessee

Bannariamman Educational Trust, Coimbatore vs. ACIT Central Circle 3(2), Chennai

ITA 3311/CHNY/2024[2018-19]Status: DisposedITAT Chennai14 Aug 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3310 To 3314/Chny/2024 िनधारणवष/Assessment Years: 2017-18 To 2021-22 M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. V. The Acit, Central Circle-3(2), Chennai. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.3353 & 3354 To 3358/Chny/2024 िनधारणवष/Assessment Years: 2015-16 & 2017-18 To 2021-22 & Cross-Objection No.42/Chny/2025 (In Ita No.3353/Chny/2024) िनधारणवष/Assessment Year: 2015-16 The Acit, Central Circle-3(2), Chennai. V. M/S.Bannari Amman- Educational Trust, 1212, Trichy Road, Coimbatore-641 018. [Pan: Aaatb 1235 C] (अपीलाथ/Appellant) (यथ/Respondent/Cross Objector) Assessee By : Mr.Vikram Vijayaraghavan, Advocate (Virtual)/Ld.Ar Department By : Mr.Shiva Srinivasan, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 27.06.2025 घोषणाकतारीख /Date Of Pronouncement : 14.08.2025

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivasan, CIT/DR
Section 12ASection 132Section 133ASection 143(2)Section 153CSection 250

relied on by the assessee are not applicable to the facts of its case. ix. In fact, M/s Chettinad Products Private Limited have filed settlement application for the A.Ys. from 2015-16 to 2020-21 admitting the said amount of cash received from the assessee

Deputy Commissioner of Income Tax, Jaipur vs. Bharat Spun Pipe and Construction Company, Jaipur

In the result the appeal of the revenue in ITA no

ITA 360/JPR/2025[2017-18]Status: DisposedITAT Jaipur06 Aug 2025AY 2017-18
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Ms. Alka Gautam, (CIT) (V.C.)
Section 144BSection 147Section 148Section 148ASection 153C

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

ACIT Central Circle16, New Delhi vs. Krishna Dal Mill Pvt Ltd, New Delhi

In the result, the appeal of the revenue is partly allowed

ITA 1737/DEL/2020[2014-15]Status: DisposedITAT Delhi06 Aug 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshacit, Vs. M/S. Krishna Dal Mill Pvt. Ltd, Central Circle-16, C-19, Lawarance Road, New Delhi Pitampura, North West Delhi, Delhi-110035 (Appellant) (Respondent) Pan: Aaack0099E Assessee By : Shri Satyen Sethi, Adv Shri A. T. Panda, Ms. Gargi Sethi, Adv Shri Nirbhay Mehta, Adv Shri Aswani Gupta, Ca Revenue By: Ms. Namita Khurana, Cit-Dr (On Rotational Duty) Date Of Hearing 02/07/2025 Date Of Pronouncement 06/08/2025

For Appellant: Shri Satyen Sethi, AdvFor Respondent: Ms. Namita Khurana, CIT-Dr (on rotational duty)
Section 132Section 143(1)Section 143(3)Section 153Section 245C(1)Section 245D(1)Section 245D(4)

been only from the major shareholders and the shareholders had failed to explain the source of its investment in this project. In the Settlement Application, the assessee had declared an outflow of funds in Annexure D amounting to Rs 29,67,05,160/- for purchase of 60% shares in Sunrise ... Krishna Dal Mill Pvt. Ltd 13. The revenue contended before us that in the settlement application an outflow of funds to the tune of Rs 29,67,05,160/- was mentioned. The total information disclosed by the assessee in the settlement application along with other applicants cannot be ignored

Parkash Sachdeva, New Delhi vs. ACIT Central Circle 18, New Delhi

ITA 2889/DEL/2023[2018-19]Status: DisposedITAT Delhi05 Aug 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 143(3)Section 69A

adapters, etc. in the open market, deles as Originat Equipment Manufacturers (OEM) and sales made to Multi Service Operators(MSO). 1.1 The applicant filed settlement application for Asst. Yomp 2012-13 to 2018-19 U/R 245C(1) on 20.12.2019 ollering additional Income of Rs.34,07,00,000/- before the Commission

Ashok Bharti Goswami, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1272/PUN/2024[2018-19]Status: DisposedITAT Pune14 Jul 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon’ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Ashish Ramesh Oswal, Pune vs. ACIT, Central Circle 2(1), Pune

ITA 1271/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon'ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Adish Shantilal Solanki, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

ITA 1270/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon'ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Chitra Narendra Parmar, Pune vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1269/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon’ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Ramlal Bhikulal Shah, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1268/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon’ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Deepak Kantilal Jain, Pune vs. ACIT, Central Circle 2(1), Pune

The appeal stands dismissed

ITA 1267/PUN/2024[2017-18]Status: DisposedITAT Pune14 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon'ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Ashish Ramesh Oswal, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1266/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon’ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Deepak Kantilal Jain, Pune vs. ACIT, Central Circle 2(1), Pune

The appeal stands dismissed

ITA 1265/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon'ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons

Ramanlal Bhikulal Shah, Pune vs. ACIT, Central Circle 2(1), Pune

In the result, all the appeals filed by the respective assessees are allowed

ITA 1264/PUN/2024[2016-17]Status: DisposedITAT Pune14 Jul 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: S/Shri Kishor B Phadke &For Respondent: S/Shri Sandeep Sengupta, CIT &
Section 131Section 132Section 142(1)Section 143(1)Section 153C

submitted that the Settlement Commission has exclusive jurisdiction over a case once such case is admitted and for the period for which such settlement application is permitted to be continued with. Therefore, once such jurisdiction is so assumed by the Settlement Commission, as a sequel, the jurisdiction of the Assessing ... ITSC (2012) 348 ITR 86 (Del), he submitted that the Hon’ble High Court in the said decision has held that where in a settlement application certain seized papers were referred to which belonged to third persons, such seized papers can be used and utilized against such third persons