COMMISSIONER OF INCOME TAX (CENTRAL) CALCUTTA vs B. N.BHATTACHARJEE & ANR.

The Supreme Court held that the Settlement Commission under the Income Tax Act, 1961, does not have the power to review its own decisions once it has declined to proceed with an application for settlement under Section 245D(1). The Court clarified that the Commissioner’s report objecting to the application is valid despite the withdrawal of departmental appeals, and the principle of estoppel does not prevent the Commissioner from exercising his statutory powers. The appeals were allowed, affirming the validity of the Commissioner’s actions under the Income Tax Act.