Literal interpretation of language of Section 245A of Income Tax Act is justified

Sushil Kumar Goyal Vs PCIT (Delhi High Court) Delhi High Court held that the legislative history of Section 245A of the Income Tax Act indicates that the proceedings for assessment, re-assessment and re-computation u/s. 148, prior to issuance of notice u/s. 148 of the Act, were excluded from the scope of the definition of the term ‘case’. Literal interpretation of language of section 245A is justifiable. Facts- The petitioners have filed the present petition impugning orders dated 06.02.2017 and 09.02.2017 passed by the Income Tax Settlement Commission (hereafter ‘the Commission’) unde...