N. CHELLAKUTTY Vs. THE INCOME TAX SETTLEMENT COMMISSION

JUDGEMENT

(1.) Heard Mr. R. Kumar, the learned counsel appearing for the petitioner and Mr. A.P. Srinivas, learned Senior Standing counsel appearing for the respondents in these writ petitions.

(2.) The petitioner has challenged the common order passed by the Settlement Commission [IT and WT], Additional Bench, Chennai, in respect of the three applications filed by the petitioners. The Assessment years to which the petitioners filed applications for settlement are 1990-91 to 2000-01, 1994-95, 1996-97 and 1992-93 to 1994-95.

(3.) The Challenge to the impugned proceedings is not on the merits of the findings recorded by the Commissioner, but only with regard to the levy of interest under sections 234 (A) and 234 (B) of the Income Tax Act,1961 [hereinafter called as "the Act"]. One other issue is with regard to the interest payable under Section 220 (2) of the Act.