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The High Court judgment relates to three appeals for the assessment years 1985-86, 1986-87, and 1987-88. The Settlement Commission's order under section 245D(4) of the IT Act, 1961, detailed the computation, directing the AO to strictly follow it for recovery. The AO cannot charge interest under section 220(2) not indicated in the Settlement Commission's order. The Tribunal, first appellate authority, and AO's orders are quashed and set aside.
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