1A question of seminal importance relating to the period for which interest in terms of S.234B of the Income Tax, Act, 1961 (in short 'the Act') can be levied when the Settlement Commission (in short 'the Commission') passes an order under S.245D of the Act, is the subject matter of adjudication in these appeals. These appeals are directed against the common judgment of the Special Bench of the Commission (in Gulraj Engineering Construction Co. In Re and Others (1995 (215) ITR ATS1) which dealt with five situations where such questions may arise. The situations according to the Special Bench are as follows:
"(i) The income is determined under S.143(1) but no regular assessment under S.143(3) or 144 is made with or without there being a notice under S.143(2) and / or S.142(1).
(ii) A regular assessment is made under S.143(3) or S.144 in addition to the determination of the income under S.143(1) and an appeal is pending before the first appellate authority.
(iii) Only a return of income is furnished without or in pursuance of a notice under S.142(1) or S.148 and the income is neither determined under S.143(1) nor under S.143(3) or S.144.
(iv) The assessment made under S.143(3) or S.144 i