Unexplained delay in challenging Settlement Commission orders barred writ interference, leaving the assessee's settlement relief undisturbed.

Revenue's delayed writ challenge to the Settlement Commission's orders was not maintainable because it had knowledge of the settlement order when made, yet sought rectification only after five years and filed the writ petition seven years after the order. The delay was inadequately explained, and no basis for writ interference with either the settlement or rectification orders was established. The challenge was therefore rejected in favour of the assessee.

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Issues: Whether the Revenue's delayed challenge to the Settlement Commission's orders warranted interference under writ jurisdiction.

Analysis: The Revenue was present when the settlement order was made and therefore had knowledge of it. Its rectification application was made after five years and rejected; the writ petition was filed seven years after the settlement order and two years after the rectification order. The delay was not properly explained, and no ground for interference with the impugned orders was made out.

Conclusion: The delayed writ challenge to the Settlement Commission's orders was not maintainable for interference and was decided in favour of the assessee.

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