In absence of Section 148 notice Section 245C(1) settlement application was invalid

Bishan Das Goyal HUF Vs Pr. Commissioner Of Income Tax (Delhi High Court) Question that falls for consideration of this Court is whether the Commission had erred in rejecting the petitioner’s application under Section 245C(1) of the Act in respect of the Assessment Years 2012-13, 2013-14 and 2014-15. Admittedly, the time for the Assessing Officer to make an assessment pursuant to the returns filed by the petitioner under Section 139 of the Act in respect of the Assessment Years 2012-13, 2013-14 & 2014-15 had expired and no notice was issued under Section 148 of the Act for assessment, re...