Judgment

KRISHNA IYER, J.:- A nascent Chapter (Chapter XIXA) in the Income-tax Act, 1961, enacted by the Taxation Laws (Amendment) Act, 1975, whose beneficiaries are ordinarily those whose tax liability is astronomical and criminal culpability perilous, falls for decoding by this Court in the appeal by the Commr. of Income-tax (Central), Calcutta, against an adverse order made by the Settlement Commission. Functionally speaking, this Chapter, engrafted in partial implementation of the Wanchoo Committee Report, provides for settlement of huge tax disputes and immunity from criminal proceedings by a Commission to be constituted by the Central Government when approached without objection from the Tax Department. It is based on the debatable policy, fraught with dubious potentialities in the context of Third World conditions of political peculium and bureaucratic abetment, that composition and collection of public revenue from tycoons is better than prosecution of their tax-related crime and litigation for total revenue recovery. A social audit of the working of this Chapter in action and its fall-out may benefit the nation by information about who the true beneficiaries of this legisla