JUDGMENT

H.L. DATTU, CJI

1. This appeal is directed against the judgment and order passed by the High Court of Judicature at Bombay in Writ Petition No. 2226 of 1989, dated 03.02.2006, whereby and whereunder, the High Court has held that the appellant is liable for payment of tax under Bombay Sales Tax Act, 1959 (for short, “the Act”) and dismissed the writ petition.

2. The question raised before us is whether the respondent-Revenue could resile from a settlement entered into with the assessee on the basis of which the appellant has already paid and settled his dues under the Act.

3. Since the protracted proceedings in the instant case have spawned over three decades, we would only notice the most relevant facts necessary for disposal of the appeal.

4. Facts in brief are as follows: The appellant had joined as a partner in the assessee-Firm. His status as the partner of the said Firm, not being of any consequence to the question that arises for our consideration, does not require to be noticed by us. The relevant assessment years are Samvat 2034 (12.11.1977 to 31.10.1978) and Samvat 2035 (01.11.1978 to 24.06.1979). The Assessing Authority had carried out the assessments and confirmed t