https://www.taxtmi.com/caselaws?id=760986 The settlement scheme under Chapter XIX-A rests on full and true disclosure and cooperation, and those same findings support both computation of settled income under Section 245D(4) and immunity from prosecution and penalty under Section 245H. Where the Settlement Commission accepted the disclosures, conducted joint verification, and did not find want of disclosure or cooperation, the immunity component could not be isolated and reopened separately. In view of the finality attached to settlement orders under Section 245I, interference under Article 226 remains limited to grave procedural defect, breach of natural justice, or a decision lacking rational nexus. A challenge confined only to immunity was therefore not maintainable. en-us Mon, 28 Oct 2024 00:00:00 +0530 Mon, 09 Jun 2025 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760986 The settlement scheme under Chapter XIX-A rests on full and true disclosure and cooperation, and those same findings support both computation of settled income under Section 245D(4) and immunity from prosecution and penalty under Section 245H. Where the Settlement Commission accepted the disclosures, conducted joint verification, and did not find want of disclosure or cooperation, the immunity component could not be isolated and reopened separately. In view of the finality attached to settlement orders under Section 245I, interference under Article 226 remains limited to grave procedural defect, breach of natural justice, or a decision lacking rational nexus. A challenge confined only to immunity was therefore not maintainable. Case-Laws Income Tax Mon, 28 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760986