Limited writ review of Settlement Commission orders bars reappreciation of facts or substitution of income-estimation methods.

Writ interference with a Settlement Commission order is limited to grave procedural defect, violation of natural justice, absence of nexus between reasons and decision, or a decision contrary to the Act. Where the assessee had retracted an earlier admission, the Commission relied on search materials and adopted an income-estimation method used in a comparable case, its findings were treated as factual and not shown to be perverse or arbitrary. The High Court would not reappreciate evidence or substitute its own view on the estimation method. The article therefore states that no legal infirmity was made out to justify interference.

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Issues: Whether the High Court could interfere under writ jurisdiction with the Settlement Commission's order on the ground that it did not accept the assessee's voluntary statement and adopted a different method for estimating income.

Analysis: The scope of interference with an order of the Settlement Commission is narrow. Interference is warranted only where there is a grave procedural defect, violation of natural justice, absence of nexus between reasons and decision, or a decision contrary to the Act. The Commission recorded that the assessee had retracted the earlier admission, considered the search materials, and adopted a method already applied in a comparable case. These findings were factual and not shown to be perverse, arbitrary, or unsupported by the record. In writ jurisdiction, the Court would not reappreciate facts or substitute its own view on the method of income estimation.

Conclusion: The Settlement Commission's order did not suffer from any legal infirmity warranting interference, and the writ petition was liable to be dismissed.

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