SANDEEP SINGH vs UNION OF INDIA

The Supreme Court addressed the issue of immunity from prosecution under Section 245H(1A) of the Income Tax Act, 1961, determining that immunity is withdrawn if payments are not made within the specified time. In this case, although the appellant did not make payments by the original deadline, the Court noted that all payments were made before the appeal was filed. The Court held that it was unnecessary to refer the matter back to the Settlement Commissioner for an extension of time, as the payments had been completed, thus allowing the appeal.