Bench: HON'BLE MRS. JUSTICE B.V. NAGARATHNA
148 of the Act. The appellant filed returns under protest with respect to the said assessment years. 2.5. Before the Settlement Commission, the Respondents-Revenue raised a preliminary objection contending that the appellant did not fulfil the qualifying criteria as contemplated under Section 245C(1) and hence, the application filed by the appellant was not maintainable, as, under the said