Settlement Commission Cannot invoke S. 154 of Income Tax to Rectify Concluded Proceedings or Levy Interest Prior to 2011: Madras HC

The Madras High Court held that the Settlement Commission cannot invoke Section 154 of the Income Tax Act to rectify concluded proceedings or levy interest prior to 2011. The court clarified that such powers are not applicable post the conclusion of assessment proceedings. The ruling aims to maintain the sanctity of finalized tax assessments and prevents arbitrary adjustments by the authorities. It reinforces that the Settlement Commission's authority is limited when dealing with past decisions, protecting taxpayers from retrospective penal actions and ensuring clarity on the jurisdictional limits of tax authorities.