Allowing the appeal of the assessee the Tribunal held that ; Order passed by Settlement Commission under S.245D(4) shall be conclusive as to matter covered therein and no matter covered by such order shall be reopened in any proceeding under Income tax Act or under any other law for time being in force, accordingly the order of CIT(A) was seta side . ( AY.2004-05)
Shree Ganpati Synthetics (P.) Ltd. v. ACIT (2018) 168 ITD 357 (Asr) (Trib.)
S. 245-I : Settlement Commission – Conclusive – Order passed by Settlement Commission under S.245D(4) shall be conclusive as to matter covered therein and no matter covered by such order shall be reopened in any proceeding under Income tax Act or under any other law for time being in force. [ S. 245C, 245D(4) , 245E ]