1. This writ petition has been preferred challenging the order passed by the Settlement Commission dated 27th/28th June, 2013 under Section 245-D(4) of the Income Tax Act, 1961 (hereinafter referred to as the Act, 1961 for the sake of brevity) which is at Annexure-6 to the memo of this writ petition. By this order additions have been made of Rs. 62,50,000/- and Rs. 73,50,663/- in respect of assessment years 2010-11 and 2011-12 respectively, over and above income declared by this petitioner in its settlement application preferred for the aforesaid period under Section 245-C(1) of the Act, 1961.

2. Factual Matrix

(i) Petitioner filed Returns for the assessment years 2010-11 and 2011-12 on 23rd September, 2010 and 29th September, 2011, respectively.

(ii) Survey under Section 133-A of the Act, 1961 was conducted by the Income Tax Department on 21st/22nd October, 2011.

(iii) This petitioner preferred settlement application under Section 245-(C)(1) of the Act, 1961 before the Settlement Commission. Alongwith this application this petitioner is also paying income tax with interest at Rs. 38,45,471/- on disclosure of additional income of Rs. 1,04,00,000/-.

(iv) The Settlement Commis