In writ petition, revenue challenged order passed by Settlement Commission only on basis of a single observation made in order that it was not practicable for Commission to examine records and investigate cases for proper settlement. Dismissing the petition the Court held that settlement was just, fair and proper and in interest of revenue and stood accepted without any protest or demur. After a period of one year from settlement, revenue could not be allowed to raise said technical plea, as with mere change of Revenue Officer, opinion cannot be allowed to change. (AY. 1999-2000 to 2005 -06)
CIT v. ITSC (2021) 276 Taxman 124 (Patna)(HC)
S. 245D : Settlement Commission-After a period of one year from settlement, revenue could not be allowed to raise said technical plea, as with mere change of Revenue Officer, opinion cannot be allowed to change. [S. 245C, 245D(4), Art.226]