(1.) Since the facts are similar, we may record those arising in Special Civil Application No.15097/2004.
(2.) The petitioner has challenged an order dated 11.10.2002 passed by the Settlement Commission in the following background :
(3.) It could thus be seen that the Commission Settlement modified its direction with respect to charging of interest exercising powers of rectification. The Supreme Court in case of Brij Lal and others v. Commissioner of Incometax, 2010 328 ITR 477), held that the Settlement Commission had no power of rectification.