Settlement Commission is given power U/s. 245H to reduce penalty but same need to be exercised judiciously and not arbitrarily

RELEVANT PARAGRAPH In perusal of the record, particularly different reports submitted by the Commissioner to the Settlement Commission and the final order passed by the Settlement Commission, it is no more in dispute that after the search of the premises of the Ajmera group as well as their accountant Vora on two occasions, application for settlement under Section 245C was made on 30th September, 1993 wherein additional income of Rs.1.94 crore was disclosed with confidential annexure. After receipt of that application, under Section 245D(1), report of the Income-tax Commissioner was called and...