Shatrusailya Digvijaysingh Jadeja vs Commissioner Of Income Tax,Rajkot

The Supreme Court upheld the Gujarat High Court's decision that the declarations filed by the appellant under Section 88 of the Kar Vivad Samadhan Scheme, 1998 were competent, directing the designated authority (DA) to determine the amount payable under Section 90(1). However, the Court set aside the additional direction requiring the appellant to pay interest on the amount payable, ruling that no interest could be charged until the amount was ascertained by the DA, as the liability only arose post-assessment. The Court clarified that the DA's error in rejecting the declarations should not penalize the appellant with interest charges.