Commissioner Of Income Tax,Rajkot vs Shatrusailya Digvijaysingh Jadeja

The Supreme Court ruled that the rejection of the declarations under the Kar Vivad Samadhan Scheme by the department was justified, as the assessments had become final in the year 1992-93 due to the dismissal of appeals for failure to pre-deposit self-assessed tax. The Court held that the revisions filed by the respondent-assessee in 1998 were time-barred and thus not 'pending' as per Section 95(i)(c) of the Scheme. Consequently, the Court upheld the department's decision to reject the declarations.