Settlement Commission not empowered to change head of income

Khazana Jewellery Pvt. Ltd. Vs Income Tax Settlement Commission (Madras High Court)

Madras High Court held that Settlement Commission doesn’t possess power to change the head of income and convert the undisclosed portion of income into income u/s. 699B. Further, Settlement application is bound to be rejected once Settlement Commission arrives at the conclusion that full and true disclosure is not done.

Facts- The petitioner-Company is engaged in the business of manufacturing and trade of jewels. A search, u/s. 132 of the Income Tax Act, 1961, was carried

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