https://www.taxtmi.com/caselaws?id=13519 The High Court's Article 226 jurisdiction over a Settlement Commission order under Chapter XIX-A of the Income-tax Act is limited, and it will not reappreciate evidence or substitute its own estimation for the Commission's factual determination. Where the Commission bases its income and tax assessment on the materials on record, interference is justified only if a patent mistake appears on the face of the record. On the facts noted, the Commission's estimate of net profit at 0.75% of turnover was founded on the search material, the absence of audited regular accounts, and incomplete seized records, so writ interference was unwarranted and the challenge failed. en-us Tue, 27 Feb 2007 00:00:00 +0530 Fri, 29 May 2009 12:54:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13519 The High Court's Article 226 jurisdiction over a Settlement Commission order under Chapter XIX-A of the Income-tax Act is limited, and it will not reappreciate evidence or substitute its own estimation for the Commission's factual determination. Where the Commission bases its income and tax assessment on the materials on record, interference is justified only if a patent mistake appears on the face of the record. On the facts noted, the Commission's estimate of net profit at 0.75% of turnover was founded on the search material, the absence of audited regular accounts, and incomplete seized records, so writ interference was unwarranted and the challenge failed. Case-Laws Income Tax Tue, 27 Feb 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13519