CIT (Central) & Anr. Vs RNS Infrastructure Limited (Supreme Court of India)
The litigation arose from settlement proceedings initiated by RNS Infrastructure Limited, an infrastructure development and construction company, following a search under Section 132 of the Income-tax Act, 1961. The assessee had filed returns for assessment years 2006-07 to 2012-13 and, during pending assessment proceedings, approached the Income Tax Settlement Commission under Section 245C, offering additional income of Rs.16,80,07,102/- for assessment years 2008-09 to 2012-13.
Read HC Judgment in this Case: Karnataka HC Quashes Settlement Commission Order Passed Beyond Statutory Time Limit
The Settlement Commission allowed the application to proceed and subsequently declared it valid. Revenue challenged the validity order before the Karnataka High Court, but the writ petitions were dismissed on 18.01.2016 and the ensuing writ appeals were withdrawn on 28.09.2016. Meanwhile, the Settlement Commission passed its final order under Section 245D(4) on 27.05.2016 determining total income and tax liability. The assessee’s rectification application was rejected on 11.08.2016.
The assessee challenged the Settlement Commission’s orders before the Single Judge, who allowed the writ petitions and quashed the order dated 27.05.2016, the rectification order dated 11.08.2016 and consequential orders and demand notices. Revenue appealed under Section 4 of the Karnataka High Court Act, 1961.
