Tax Settlement Order Can't Rectify Interest Levy Before 2011 or Reopen Concluded Proceedings.

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....Settlement Commission lacks power to rectify order u/s 245F(1) by levying interest u/ss 234A, 234B, and 234C prior to 01.06.2011. Rectification order on 21.03.2003 was invalid as Settlement Commission did not have rectification power then. Supreme Court in Brij Lal case held interest u/s 234B is leviable only till date of order u/s 245D(1), not till Settlement Order u/s 245D(4). Settlement Commission cannot reopen concluded proceedings invoking Section 154 to levy interest u/s 234B due to Section 245I restriction.....