Settlement Commission's Powers Don't Make It an Adjudicating Authority in Tax Matters.

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....The conferment, on the Settlement Commission, of the “powers of a Customs officer”, or the “powers of the Central Excise Officer” would not, ipso facto, result in the Settlement Commission metamorphosing into an adjudicating authority. - The Settlement Commission does not, by the conferment of such power, become a parallel adjudicating authority, adjudicating the Show Cause Notice....