https://www.taxtmi.com/caselaws?id=763245 Chapter XIXA settlement proceedings under the Income-tax Act operate as a distinct statutory mechanism based on full and true disclosure, and the Settlement Commission's order is conclusive on the matters covered by the application and related issues in the Commissioner's report. Judicial review under Article 226 is narrow: the High Court may interfere only for statutory illegality, grave procedural defect, bias, fraud, malice, or absence of nexus between reasons and decision, and it cannot reappreciate facts or sit in appeal over the Commission's merits-based findings. Because a settlement is composite, an assessee cannot accept favourable parts while challenging an adverse component in isolation. The challenge to the treatment of loan receipts as undisclosed income therefore did not justify interference, and the settlement order was upheld. en-us Thu, 12 Dec 2024 00:00:00 +0530 Sat, 14 Dec 2024 10:01:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763245 Chapter XIXA settlement proceedings under the Income-tax Act operate as a distinct statutory mechanism based on full and true disclosure, and the Settlement Commission's order is conclusive on the matters covered by the application and related issues in the Commissioner's report. Judicial review under Article 226 is narrow: the High Court may interfere only for statutory illegality, grave procedural defect, bias, fraud, malice, or absence of nexus between reasons and decision, and it cannot reappreciate facts or sit in appeal over the Commission's merits-based findings. Because a settlement is composite, an assessee cannot accept favourable parts while challenging an adverse component in isolation. The challenge to the treatment of loan receipts as undisclosed income therefore did not justify interference, and the settlement order was upheld. Case-Laws Income Tax Thu, 12 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763245