In Brief
A taxpayer entered into a settlement under the Income Tax Act, 1961 but failed to pay the settlement amount by the originally fixed deadline. However, he made all payments before filing an appeal to the Supreme Court. The Supreme Court held that immunity from prosecution under Section 245H(1A) should not be withdrawn in these circumstances. Since payments were completed before the appeal was filed, the Court treated them as made within the permitted timeframe, without requiring the appellant to seek formal enlargement of time from the Settlement Commissioner. The appeal was allowed.
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