The group of assessee’s with as many as 1500 search cases assessments managed settlement in their cases after a high court directive in 447ITR769 (SC). The settlement order however is challenged by the department to high court and then by the the assessee’s to the Supreme Court which ultimately held for denovo adjudication to the interim board u/s245AA.
What prompted this has been a word of qualification made in the settlement order of the members practical inability to provide proper and sufficient opportunity to either side only because of heavy paperbooks such as in one group containing 30000 pages.
Size of the paper books may sometime be more dreadful than delightful and therefore ought to be made with caution and care.
This U-turn order after 15 years whether would benefit revenue either who has already collected amount of taxes as per settlement order of 2008!!