Case Law Analysis
|Allahabad High Court
18-Month Limitation Under Sec 245D(4A)(iii) Is Mandatory, Not Reset by Transfer | Income-Tax Settlement Applications : Allahabad HC
The Allahabad High Court ruled that the 18-month limitation in Sec 245D(4A)(iii) starts at the initial filing of a pending settlement application and cannot be reset by transferring the case, rendering the Interim Board’s October 2023 order time-barred and void. Taxpayers can no longer revive stale settlement applications by shifting them between boards.