Smt. Sushila Rani vs Commissioner Of Income Tax & Anr

The Supreme Court held that under the Income Tax Act, 1961, specifically Sections 90(1) and 90(2) of the Kar Vivad Samadhan Scheme, 1998, the appellant was entitled to a refund of excess tax paid after the issuance of a statutory certificate. The Court emphasized the mandatory nature of Section 245, which requires notice to the assessee before adjustments are made, and ruled that the adjustments made without notice were invalid. The Court directed the Department to process the refund claim of the appellant, thereby upholding the principles of fair procedure and compliance with statutory requirements.