Prior Cutoff Date Not Applicable u/s 245C Income Tax Act for Settlement Application: Kerala HC

The Kerala High Court has ruled that a prior cutoff date is not applicable under Section 245C of the Income Tax Act for settlement applications. This means that taxpayers seeking settlement of their income tax cases through the Settlement Commission are not bound by an arbitrary past date for their undisclosed income or assets. The decision clarifies that the focus should be on the voluntary disclosure and full cooperation of the assessee at the time of application, rather than a fixed historical date. This ruling provides greater flexibility for taxpayers to approach the Settlement Commission, promoting resolution of complex tax disputes.