Limited judicial review of Settlement Commission orders prevents writ courts from reappreciating disclosure and valuation findings.

The writ court's interference with a Settlement Commission order is limited to serious error in decision-making, perversity, or jurisdictional illegality, and it cannot substitute its own view on valuation or disclosure. Here, the Settlement Commission gave reasons for rejecting the assessee's reliance on alleged duplicate books as incomplete and unreliable, and it plausibly adopted the net accretion to asset method while accepting the assessee's year-wise working. Additional disclosure made during settlement proceedings, in the context of the Commission's directions and the assessee's cooperation, did not by itself negate full and true disclosure at the threshold. The writ court's interference was therefore unsustainable, and the Commission's order was restored.

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Issues: Whether the writ court could interfere with the Settlement Commission's order on the ground that the assessee had not made full and true disclosure and that the valuation method adopted by the Settlement Commission was perverse.

Analysis: The settlement mechanism under Chapter XIXA of the Income-tax Act, 1961 is a special statutory process intended to enable settlement of cases on disclosure and payment of tax, and the scope of judicial review is confined to examining whether there is any serious error in the decision-making process, perversity, or illegality. The Settlement Commission had given reasons for rejecting the objection based on the so-called duplicate books, noting that they were incomplete and unreliable, and had also given plausible reasons for adopting the net accretion to asset method and for accepting the assessee's year-wise working. The later additional disclosure made during the settlement proceedings, in the context of the Commission's directions and the assessee's cooperation, did not by itself establish absence of full and true disclosure at the threshold.

Conclusion: The interference by the writ court was unsustainable, and the Settlement Commission's order was restored in favour of the assessee.

Ratio Decidendi: A writ court cannot substitute its own view for that of the Settlement Commission unless the impugned order discloses a serious error in decision-making, perversity, or jurisdictional illegality; additional disclosure made during settlement proceedings does not automatically negate full and true disclosure.

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