Finding Fact of Settlement Commission is not Open to Judicial Review

A finding of fact made by the Settlement Commission is not open to judicial review unless it is established that, such finding of fact suffers from perversity or is vitiated due to bias or malice. None of the grounds known to law to upset a finding of fact returned by a Settlement Commission has been substantiated in the facts of the present case. The findings of the Settlement Commission on the correctness of the disclosures made by the assessee before it have not been substantiated to be perverse. The contention that, the Settlement Commission ought to have arrived at the tax liability on th...