JUDGMENT :

DINESH KUMAR SINGH, J.

1. The present writ petition has been filed by the petitioner, who is the Managing Director of M/s Delta Aggregators and Sand Pvt. Ltd. with 70% shareholding and M/s Delta Msand Pvt. Ltd. with 70% shareholding impugning the Order passed by the Settlement Commission dated 22.12.2023 in Ext.P8 in respect of the Assessment Years 2012-13 to 2018-19.

2. A search and seizure action under Section 132 of the Income Tax Act 1961 (for short, ‘the Act’) was carried out on 13.10.2017 at several premises of the Delta Group and the petitioner’s residence. Consequent to the search, notices under Section 153A were issued on 07.06.2018 to the aforesaid two companies as well as to the petitioner for the Assessment Years 2012-13 to 2017-18. Notice under Section 143(2) was issued on 23.09.2019 for the Assessment Year 2018-19.

2.1 The petitioner had filed Settlement Applications twice, i.e. on 26.12.2019 and 02.03.2020, respectively, before the Settlement Commission. However, the same was rejected on account of the failure of the petitioner to satisfy the criteria prescribed under Section 245(1) of the Act. Thereafter, the petitioner filed another application for the third