Assessee filed an application under section 245C admitting undisclosed income of certain amount towards remuneration earned outside banking channels which  was admitted.  Assessing Officer in his report opined that assessee had not disclosed an additional income to extent of certain amount.  Settlement Commission (IBS) passed a final order settling income of assessee at certain amount. Assessee filed a writ petition on issue of loan amount received by assessee from two companies in which it was a shareholder, which IBS considered as deemed divided income of assessee under section 2(22) which was dismissed  by a single judge, on finding that there was no scope for interfering with impugned order of IBS in proceedings under article 226.   On appeal against the order of the single judge, dismissing the appeal the Court held that the assessee might be able to demonstrate that loans availed by him for sister concerns were for furtherance of business of group as a whole, and therefore, would not attract concept of deemed dividend, fact remained that from another perspective said amount could be seen as income that was not disclosed for purposes of settlement.  Further, defect that vitiate a settlement must be one that vitiate whole and not merely any one part of settlement. Therefore a partial acceptance of a settlement is not envisaged under I.T. Act, and courts must defer to that scheme of statutory finality envisaged for settlement under I.T. Act while exercising jurisdiction of judicial review under article 226. Order of single judge is affirmed. (AY. 2012-13 to 2017-18)