Settlement application discretion under Income-tax law upheld where no complex pending investigation justified Commission intervention.

Admission of a settlement application under section 245C is discretionary and depends on the facts of each case, including whether any pending investigation is of sufficient complexity to justify Settlement Commission intervention. The High Court found that the Commission had given cogent reasons, including that most disputed issues concerning business ownership had already been settled and no such complex investigation remained. As no infirmity in the order was shown, interference under Article 226 was unwarranted. The rejection of the settlement application was therefore upheld, and the writ petition was dismissed, leaving the petitioner to pursue the issues in pending appellate proceedings.

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Issues: Whether the rejection of the settlement application under section 245C of the Income-tax Act, 1961 was justified on the facts and whether interference was warranted in writ jurisdiction under Article 226 of the Constitution of India.

Analysis: The admission of a settlement application under section 245C depends on the facts and circumstances of each case. The Commission had recorded cogent reasons that most of the controversial issues regarding ownership of the business had already been settled and that there was no pending investigation of such a complex nature as would justify intervention by the Settlement Commission. The order was not shown to suffer from any infirmity warranting interference, and the petitioner could pursue the issues in the pending appellate proceedings.

Conclusion: The rejection of the settlement application was upheld and the writ petition was rejected.

Ratio Decidendi: Admission of a settlement application under section 245C is discretionary and depends on whether there remains a pending investigation of sufficient complexity to justify the Settlement Commission's intervention.

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