Settlement finality and interest waiver cannot be reopened through rectification once proceedings have concluded.

A settlement commission cannot use Section 154 of the Income-tax Act to reopen concluded settlement proceedings or withdraw a waiver of interest under Sections 234B and 234C once the settlement application has been allowed to proceed. The legal position, as reflected in the Supreme Court ruling discussed, is that further charge of interest under Section 234B is not permissible after such settlement, and rectification cannot be used to unsettle finality. The impugned order and consequential demand notices were therefore inconsistent with the settled rule governing final settlement proceedings and interest liability.

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Issues: Whether the Settlement Commission could reopen concluded settlement proceedings by invoking the rectification power under Section 154 of the Income-tax Act, 1961 and withdraw the waiver of interest under Sections 234B and 234C.

Analysis: The dispute turned on the effect of the Supreme Court's ruling that, once an application for settlement is allowed to proceed, further charge of interest under Section 234B is not permissible and the power under Section 154 cannot be used to reopen the settled matter. The impugned order and the consequential demand notices were thus inconsistent with the settled legal position governing finality of settlement proceedings and interest liability.

Conclusion: The reopening of the concluded settlement proceedings was impermissible, and the withdrawal of waiver of interest under Sections 234B and 234C could not be sustained.

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