Settlement Commission final order bars unilateral reopening under section 153A where statutory challenge routes were not used.

A final settlement order under section 245D(4) rendered the matters covered for the assessment year conclusive, and any challenge to that settlement had to proceed through the statutory remedies under section 245D, including fraud, misrepresentation, or rectification of mistake. The Tribunal held that reopening the completed assessment under section 153A, without following that prescribed route, was beyond jurisdiction. The reassessment was therefore treated as invalid, and the Revenue's challenge failed.

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Issues: Whether the Revenue could reopen and reassess the assessee's completed assessment under section 153A after the Settlement Commission had passed a final order under section 245D(4) for the same assessment year.

Analysis: The application for settlement had been admitted and a final order had been passed by the Settlement Commission, followed by an order giving effect to that settlement. The statutory scheme made the settlement order conclusive for the matters covered for that assessment year, and any challenge to such settlement had to follow the procedure under section 245D, including cases of fraud, misrepresentation, or rectification of mistake. The Tribunal found that the Assessing Officer did not invoke the prescribed statutory route and instead reopened the matter under section 153A on his own, which was beyond jurisdiction.

Conclusion: The reassessment under section 153A was held to be without jurisdiction and the Revenue's challenge failed.

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