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2013 (2) TMI 400 - PUNJAB AND HARYANA HIGH COURTWhether the Settlement Commission could reopen its concluded proceedings by invoking Section 154 so as to levy interest u/s 234B Held that:- Following the decision in case of Brij Lal (2010 (10) TMI 8 - SUPREME COURT) that as per Sec. 245-I the order of the Settlement Commission is made final and conclusive on matters mentioned in the application for settlement except in the two cases of fraud and misrepresentation in which case the matter could be reopened by way of review or recall. Thus, Settlement Commission cannot reopen its concluded proceedings by invoking Section 154. One must keep in mind the difference between review/recall of the order and rectification under section 154. The schedule of Chapter XIX-A does not contemplate invocation of section 154 otherwise there would be no finality to the assessment by settlement which is different from assessment under Chapter XIV where there is an appeal, revision, etc. Settlement of liability and not determination of liability is the object of Chapter XIX-A. In favour of assessee
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