Allowing the petition the Court held that the issues pertaining to the valuation of work-in-progress as well as disallowance of interest were considered at the stage of proceedings before the Settlement Commission, which had recorded the findings in its final order dated September 16, 2016. Therefore, the contention raised by the Principal Commissioner that the escapement of income was not brought to the notice of the Settlement Commission, was not justified. Additionally, it could be seen that both the issues did not form the subject matter of the challenge against the final order of the Settlement Commission as they were concerned with (i) granting immunity from penalty and prosecution under section 245H of the Act and (ii) granting waiver of interest under section 234A of the Act. Hence the notice under section 148A was not valid. Referred,   Brij Lal v. CIT (2010) 328 ITR 477  (SC)  wherein the Court held that  the finality of the order of the Settlement Commission emanates from section 245-I of the Income-tax Act, 1961 which envisages that every order of settlement passed under sub-section (4) of section 245D shall be conclusive as to the matters stated therein and no matter covered by such order shall, save as otherwise provided in Chapter XIX-A of the Act, be reopened in any proceeding under this Act or under any other law for the time being in force.(AY.2007-08)