In Brief
The Supreme Court held that under the Delhi Tax Compliance Achievement Scheme, 2013, the power to issue show cause notices for false declarations (Clause 8) is vested exclusively in the Commissioner, not the Designated Authority (Additional Commissioner). A Government Order was only a general empowerment to decide initial applications, not a delegation of powers to reopen concluded matters. Although the Additional Commissioner lacked jurisdiction, the Court set aside the High Court's order granting the assessee relief. The assessee had failed to raise jurisdictional objections promptly and instead challenged them through writ petition only after the limitation period expired, constituting an attempt to gain unfair advantage. The Court allowed the Revenue to issue a fresh notice if so advised.
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