Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantification.

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....Judicial review of Settlement Commission orders is limited to jurisdictional or statutory infirmity, prejudice, fraud, bias or malice and cannot operate as an appellate reassessment of the underlying adjudication. Where parties voluntarily settle proceedings arising from a show cause notice without pursuing the statutory appeal, they cannot reopen the notice's validity on limitation or reasonable-period grounds by challenging a consequential interest direction. Statutory interest remains a consequence of customs duty liability despite settlement of the duty quantum. Verification and quantification of further interest by the jurisdictional Commissioner may therefore be directed, subject to any independently maintainable challenge to the statutory computation.....