Dismissing the petition the Court held that ; the concept of compounding of offences in taxation law is not unique to India. Most jurisdictions of the world do provide for such measures even when there is wilful non-payment or evasion of tax which is an offence under the respective laws. Compounding of offences cannot be taken as a matter of right. It is for the law and authorities to determine what kind of offences should be compounded, if at all, and under what conditions.( Y.P. Chawla v. M. P. Tiwari (1992) 195 ITR 607 ( SC) .On facts the application for compounding twenty years after assessment order and after framing of criminal charges therefore determination of compounding fees was held to be valid . Assessee was also directed to pay cost of Rs 50000 .