Interest demand u/s 220(2) till admission of application by Settlement Commission is valid

Brief about case

The assessment of the respondent-assessee was made on 30.01.2002 determining undisclosed income of Rs.1,40,02,500/- u/s 158BD of the Income Tax Act. During the course of assessment proceedings, the assessee had filed application before the Settlement Commission on 11.5.2001 which was admitted u/s 245D(1) on 16.09.2002. Final order assessing the undisclosed income to Rs.32,20,000/- was passed by settlement commission on 30.09.2005. The Assessee paid the demand within 30 days. On 14th December,

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