Finality of settlement proceedings bars fresh additions on the same seized material after settlement order.

An order of settlement under section 245D(4) attains finality under section 245I and, read with section 245F(4), concludes the matters covered by the settlement proceedings. Where the Assessing Officer later makes a fresh assessment on the same seized material and the same period already considered by the Settlement Commission, the statutory scheme does not permit reopening or piecemeal determination of settled income in the absence of fraud or misrepresentation. The fresh additions were therefore unsustainable and were deleted.

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Issues: Whether, after an order of settlement under section 245D(4) of the Income-tax Act, 1961, the Assessing Officer could make a fresh assessment on the same period and seized material, and whether the additions made in such assessment were sustainable.

Analysis: The settlement order attained finality under section 245I and, read with section 245D(4) and section 245F(4), it concluded the matters covered by the settlement proceedings. The record showed that the assessment made by the Assessing Officer was based on the same seized documents and related income already considered in the settlement proceedings. In the absence of fraud or misrepresentation, the statutory scheme did not permit reopening of settled matters or a piecemeal determination of income by the Assessing Officer after the Settlement Commission had passed its order.

Conclusion: The Assessing Officer had no jurisdiction to make fresh additions on the settled material, and the additions were rightly deleted. The Revenue's challenge failed.

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