On writ the Court held, that the order of the Settlement Commission under section 245D on the interest accrued but not due was contrary to the provisions of law. The Settlement Commission had not given any reasons but had simply stated that it agreed with the Commissioner’s view. Reasons are live links between the mind of the decision taker to the controversy in question and the decision or conclusion arrived at. The right to receive interest on Government securities vested in the assessee only on the due date mentioned in the securities. Consequently, the interest accrued on the securities only on the due dates and had not accrued to the assessee on any date other than the dates stipulated therein. Therefore, the conclusion arrived at by the Settlement Commission was not in conformity with the provisions of law and certainly such a contravention would prejudice the assessee. The order of the Settlement Commission and the assessment order to the extent of the aspect of interest was quashed and set aside. The matter was sent to the Interim Board for Settlement constituted for the settlement of pending applications as contemplated under section 245AA. The Interim Board was directed to pass such orders as it deemed fit in accordance with law after hearing the parties. The Supreme Court in ACIT v. Saurashtra Kutch Stock Exchange Ltd (2008) 305 ITR 227  (SC) has held that a judicial decision acts retrospectively. The judges do not make law, they only discover or find the correct law. The law has always been the same and if a subsequent decision alters the earlier one, the later decision does not make a new law. It only discovers the correct principle of law which has to be applied retrospectively. The Supreme Court held that even an earlier decision of the court operated for quite sometime, the decision rendered later on would have retrospective effect, clarifying the legal position which was earlier not correctly understood. (AY.1997-98)