COMMNR. OF INCOME TAX, RAJKOT vs SHATRUSHAILYA DIGVIJAYSINGH JADEJA

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