Voluntary tax settlement cannot later be challenged under Article 32 when liability flows from the settlement itself.

A liability arising from a voluntary settlement entered into with the Government under the Taxation on Income (Investigation Commission) Act, 1947 could not later be impeached in a petition under Article 32 of the Constitution. The Court treated the assessed liability as flowing from the petitioner's own settlement, so a challenge to the procedure leading to that liability was not entertainable under Article 32. The petition was therefore held misconceived and not maintainable.

---

---

Issues: Whether a liability arising under a voluntary settlement entered into under the Taxation on Income (Investigation Commission) Act, 1947 could be challenged in a petition under Article 32 of the Constitution of India.

Analysis: The liability was held to arise from the settlement voluntarily entered into by the petitioner with the Central Government. On that basis, the challenge to the procedure leading to the assessed liability was not entertainable in a petition under Article 32, and the petition was treated as misconceived.

Conclusion: The challenge was rejected and the petition was not maintainable under Article 32.

Ratio Decidendi: A liability accepted under a voluntary settlement made with the Government cannot later be impeached by invoking Article 32.

---