JUDGMENT : Akil Abdul Hamid Kureshi, J. 1. These petitions, barring few minor differences, arise in similar background. They have been heard together and would be disposed of by this common judgment. 2. We may notice facts from Special Civil Application No. 9990 of 2016. The petitioner is a company registered under the Companies Act and is engaged in the business of bulian trading, commodity trading, real estate, share broking and other businesses. The petitioner has challenged an order dated 31.05.2016 passed by the Settlement Commission under Section 245D(4) of the Income Tax Act, 1961 ['the Act' for short]. 3. On 26.10.2012, search and seizure operation under Section 132 of the Act was carried out in case of the petitioner. This led to notices under Section 153A of the Act when issued on 06.03.2013, the petitioner filed return in response to such notice on 09.04.2013. Search and survey operations were carried out in case of one Shri Sirish C Shah ['S.C. Shah' for short] and others at Mumbai. On 01.10.2014, the Assessing Officer issued notice under Section 142(1) of the Act. On 11.11.2014, the petitioner applied for settlement by filing application for settlement of the cases for the assessment years 2008-08 to 2014-15. 4. The Settlement Commission passed an order admitting such application on 21.11.2014 in terms of Section 245D(1) of the Act. On 05.01.2015, Commissioner of Income Tax, Ahmedabad, submitted his report dated 02.01.2015 to the Settlement Commission for deciding the stage of Section 245D(2C) of the Act. On the same day, the petitioner had also filed written submissions in the proceedings fixing for hearing under Section 245D(2C) of the Act. One of the grounds taken in such submissions was that, the statement of Shri S.C. Shah recorded at Mumbai was behind the back of the petitioner and the same cannot be used against the petitioner unless and until the same is tested by cross-examination. The petitioner relied on several decisions in support of such a contention. On 09.01.2015, the Settlement Commission held that the application was not invalid, as referred to in Section 245D(2C) of the Act. 5. On 08.04.2015, the Commissioner filed a report under Rule 9 of the I.T. Settlement Commission (Procedure) Rules, 1997. The petitioner relied on several decisions in support of such a contention. On 09.01.2015, the Settlement Commission held that the application was not invalid, as referred to in Section 245D(2C) of the Act. 5. On 08.04.2015, the Commissioner filed a report under Rule 9 of the I.T. Settlement Commission (Procedure) Rules, 1997. On 18.06.2015, the petitioner filed rejoinder to the report of the department, in which also, the petitioner contended that the statements of Shri S.C. Shah and others which have been used against the petitioner without granting opportunity of cross examination was contrary to the decisions of various courts. 6. On 02.03.2016, the Settlement Commission had fixed the hearing for passing order under Section 245D(4) of the Act. The representative of the petitioner appeared but the hearing was adjourned as the Assessing Officer was held up in other urgent proceedings. Further hearing was fixed on 09.03.2016 on which date, the petitioner sought an adjournment. The department also requested for time. Further hearing was, therefore, fixed on 06.04.2016. The Settlement Commission conducted further hearings on 03.05.2016, 04.05.2016 and thereafter, kept the further hearing on 12.05.2016. 7. On 10.05.2016, the department produced a DVD containing some 1540 odd pages of data, as can be seen from a letter dated 10.05.2016 written by the Deputy Commissioner of Income Tax to the petitioner. This disc contained data worth 800 pages of one Praneta Industries Ltd. and 739 of data concerning Chandani Textile Engineering Ltd. On 12.05.2016, the petitioner therefore filed an application before the Settlement Commission and prayed for extension of hearing date, which was not granted. On 14.05.2016, the petitioner once again applied for cross-examination of different witnesses including Shri S.C. Shah. Finally, the Settlement Commission passed the impugned order, in which, the Settlement Commission held that the petitioner had not made true and full disclosures and that, the application for settlement was required to be rejected. Concluding portion of the order of the Settlement Commission reads as under: "29. Finally, the Settlement Commission passed the impugned order, in which, the Settlement Commission held that the petitioner had not made true and full disclosures and that, the application for settlement was required to be rejected. Concluding portion of the order of the Settlement Commission reads as under: "29. Findings: The facts of this case are intermingled with the facts of other 11 cases of Shri Y A Thakkar Group except M/s. Aashwina Constructions Pvt. Ltd. We have given detailed findings in the case of Shri Y.A. Thakkar and six others (S.A. No. GJ/AHCC-I/078/201-15/IT for Shri Y.A. Thakkar) in which order is being passed alongwith Shri Y.A. Thakkar is stated to be the main person of "Amrapali Group" and the Managing Director of Amrapali Industries Ltd. and Director in M/s. Aashwina Construction Pvt. Ltd., M/s. Avichal Reality Pvt. Ltd. and various other companies of "Amrapali Group." Shri Y.A. Thakkar is also stated to be advising his son Shri Chirag Y. Thakkar in the management and control of Amrapali Fincap Pvt. Ltd. and Amrapali Capital and Finance Services Ltd., wherein his son Shri Chirag Y. Thakkar is a Director. For the purposes of brevity, the findings are not being reproduced here. 30. Conclusions: Keeping in view the representations both by the applicant and the department which are discussed in detail and our findings in the case of Shri Y.A. Thakkar supra which are applicable to the present case also, our specific findings on the facts of this case are as under:- 1. The applicant has disclosed total investments in its share capital of Rs. 98.90 crores in two financial years F.Y 2007-08 and 2008-09. It has admitted that a capital of Rs. 33.14 crores is from unaccounted sources of various family members. The complete discussion of facts in this case reveals that the remaining sum also represents unaccounted income. This is a case were new capital was introduced on private placement basis. Therefore, the claim of the applicant that in view of the ratio of M/s. Lovely Exports no other addition can be made in this case is not correct since in that case decision was not given on merits it was only a refusal to admit a special leave petition. The issue is now governed with the decision of special Bench of Delhi High Court in the case of Sophia Finance ltd. The issue is now governed with the decision of special Bench of Delhi High Court in the case of Sophia Finance ltd. In view of these facts, it is considered that the true and full facts regarding the unaccounted income are not disclosed. The case of Thus, a sum of Rs. 65.76 crores (Rs. 98.90 - Rs. 33.14 crores) remains the capital invested through unaccounted sources which the department is supported by judicial pronouncements Rajmandir Estates Pvt. Ltd., v. Pr. CIT, Kolkata-III, Kolkata wherein it is held that the ITO may even be justified in trying to ascertain the source of depositor, thus confirming the principle laid down by the special Bench of the Delhi High Court in the case of Sophia Finance Ltd. 2. The applicant has disclosed an income of Rs. 17,79,119/- computed at a rate of 7 paise per Rs. 100/- on an unaccounted trade in commodities estimated to the Rs. 2134 crores. The applicant has failed to give any evidence whatsoever about the actual trade, its quantum and the capital employed for such a huge turnover. Even the rate of brokerage is very meager. Similar trades appellant is earning upto Rs. 2 per Rs. 100/- as will be seen in the next paragraph. At this rate the income could be of the order of Rs. 42 crores. In view of this discussion it can be safely concluded that the applicant has not disclosed true and full facts of this trade and the income earned. The Assessing Officer will complete the investigation on account of such income to reach to a final conclusion in this matter. 3. The applicant had disclosed a sum of Rs. 25,41,978/- earned at a rate of Rs. 2/- per Rs. 100/- in another commodity trade of Castor. This involves a turnover of more than Rs. 12.50 crores. The applicant has failed to give any evidence whatsoever about the actual trade, its quantum and the capital employed for such a huge turnover. In view of this discussion it can be safely concluded that the applicant has not disclosed true and full facts of this trade and the income earned. The Assessing Officer will complete the investigation on account of such income to reach to a final conclusion in this matter. 4. The issue relating to claim of loss in trade in the share of M/s. Chandani Textile has been narrated in great details. The Assessing Officer will complete the investigation on account of such income to reach to a final conclusion in this matter. 4. The issue relating to claim of loss in trade in the share of M/s. Chandani Textile has been narrated in great details. The applicant has been able to indicate certain mismatch in the figures to claim that the department has failed to prove that the loss in this trade was not genuine. However, two facts remain uncontroverted. Shri Shirish Chandrakant Shah an accomplice of the applicant was running an artificial trade in the share of M/s. Chandani Textile. In the excel spread sheets maintained by Shri Shirish C. Shah receipt of cash from Shri Yaswant A Thakkar is mentioned in great details, so much so that two separate accounts "commercial accounts" and "normal accounts" are maintained. The trade is being artificially managed with the use of funds provided by Shri Y.A. Thakkar. Such facts lead us to a belief that the applicant has not disclosed true facts in this instance and therefore the claim of loss is not genuine. The Assessing Officer will complete the investigation on account of such income to reach to a final conclusion in this matter. 5. Keeping in view the representations both by the applicant and the department which are discussed in details and our findings as above, we are of an opinion that this applicant has not disclosed the full and true particulars of its income. The mode by which unaccounted income is earned is also not explained since the findings of fact as discussed in the order are not corroborated by the admitted income. Accordingly, we give a finding that this petition is rejected." 8. Last relevant fact is that the petitioner had, in the meantime, approached the High Court by filing Special Civil Application No. 6837 of 2016 and connected petitions complaining about the Settlement Commission proceeding further with the hearing of the settlement applications without granting cross-examination of Shri S.C. Shah and others whose statements were being relied upon by the department. The High Court disposed of the group of petitions by an order dated 26.04.2016 as under: "6. The High Court disposed of the group of petitions by an order dated 26.04.2016 as under: "6. From the facts and contentions noted hereinabove, it is evident that the petitioners are aggrieved by the manner in which the proceedings are being conducted by the Settlement Commission on the applications made by them under section 245C(1) of the Income-tax Act, 1961. Thus, in effect and substance the petitioners seek a direction to the Settlement Commission to comply with the principles of natural justice and afford an opportunity to cross examine certain persons and to provide documents or other material relied upon by the Principal Commissioner of Income-tax in his report under rule 9 of the rules. In the opinion of this court, any direction issued by it to the Settlement Commission during the pendency of the proceedings before it would amount to dictating the manner in which the Settlement Commission should conduct the proceedings before it. In the opinion of this court, while exercising powers under Articles 226 and 227 of the Constitution of India, it is not permissible for this court to dictate the manner in which the Settlement Commission should conduct the proceedings pending before it. If the procedure followed by the Settlement Commission is contrary to the principles of natural justice or contrary to law, it is always open for the petitioner to challenge the ultimate order passed by the Settlement Commission. However, at this stage, merely on an apprehension that there is likely to be a breach of the principles of natural justice, this court would not interfere with the conduct of the proceedings before the Settlement Commission. Under the circumstances, this court is not inclined to entertain these petitions at this stage as they are premature. 7. For the foregoing reasons, without entering into the merits of the submissions advanced by the learned counsel for the petitioners, the petitions being premature are dismissed at this stage. However, all contentions raised in these petitions are kept open to be agitated in an appropriate petition at any appropriate stage." 9. Facts are similar in all cases. The common order of the Settlement Commissioner, the petitioners have challenged in this group of petitions. Learned counsel Mr. However, all contentions raised in these petitions are kept open to be agitated in an appropriate petition at any appropriate stage." 9. Facts are similar in all cases. The common order of the Settlement Commissioner, the petitioners have challenged in this group of petitions. Learned counsel Mr. R.K. Patel for the petitioners raised following contentions: "(i) That the Settlement Commission had proceeded in breach of principles of natural justice by relying upon statements of several witnesses without offering cross examination to the petitioners. The Settlement Commission also did not grant reasonable time to the petitioners though at the last stage of hearing of the cases, the department had produced voluminous additional evidence. (iii) Counsel pointed out that the issue of not providing cross-examination of witnesses and late production of data in form of DVD does not arise in Special Civil Applications No. 10000 of 2016 and 10001 of 2016. However, in such cases, as in all other petitions, additional contention of no proper verification of the materials before the Settlement Commission passed the final order, would arise. (iv) The Settlement Commission while rejecting the applications of the petitioners gave directions to the Assessing Officer to carry out assessments in a particular manner, a power which the Commissioner did not have." 10. On the other hand, learned counsel Mr. Manish Bhatt for the department opposed the petitions contending that: "(i) There was no breach of natural justice by the Settlement Commission. The Settlement Commission had not relied solely on the statements of Shri S.C. Shah and other related persons. The department had produced matching entries from the Bombay Stock Exchange in form of a DVD which was in addition to and in furtherance of the evidence already on record. Mere number of pages would not show that the evidence was voluminous or bulky. In any case, at the very outset, documents, on which, the department placed reliance were produced on 05.01.2015 alongwith the report submitted by the Commissioner and remaining documents were supplied on 08.04.2015 alongwith report under Rule 9 of the Rules. (ii) Counsel submitted that the petitioner had ample opportunity to represent the case before the Settlement Commission. The hearing, which was first fixed on 02.03.2016, was adjourned to accommodate both sides by the Commission and finally, the hearings took place on 03.05.2016, 04.05.2016 and 12.05.2016. (ii) Counsel submitted that the petitioner had ample opportunity to represent the case before the Settlement Commission. The hearing, which was first fixed on 02.03.2016, was adjourned to accommodate both sides by the Commission and finally, the hearings took place on 03.05.2016, 04.05.2016 and 12.05.2016. (iii) Counsel submitted that the finding of the Settlement Commission, that the petitioner had not made true and full disclosures, did not rely solely on the petitioners' transactions with Mr. S.C. Shah and other related persons but also included other independent transactions. The two sets of conclusions were severable. Even if, therefore, this Court were to come to the conclusion that the findings of the Settlement Commission relateable to the statements of Shri S.C. Shah and other persons were vulnerable, for want of cross-examination of such persons, the entire order of the Settlement Commission should not be struck down since the paramount requirement for a person applying for settlement is of making true and full disclosure." 11. Having thus heard learned counsel for the parties and having perused the documents on record, we may notice that the Supreme Court in case of Andaman Timber Industries v. Commissioner of Central Excise, Kolkata-II, reported in 62 Taxmann.com 3 held and observed that: "6. According to us, not allowing the assessee to cross examine the witnesses by the Adjudicating Authority though the statements of those witnesses were made the basis of the impugned order is a serious flaw which makes the order nullity inasmuch as it amounted to violation of principles of natural justice because of which the assessee was adversely affected. It is to be borne in mind that the order of the Commissioner was based upon the statements given by the aforesaid two witnesses. Even when the assessee disputed the correctness of the statements and wanted to cross examine the Adjudicating Authority did not grant this opportunity to the assessee. It would be pertinent to note that in the impugned order passed by the Adjudicating Authority he has specifically mentioned that such an opportunity was sought by the assessee. However, no such opportunity was granted and the aforesaid plea is not even dealt with by the Adjudicating Authority. As far as the Tribunal is concerned, we find that rejection of this plea is totally untenable. However, no such opportunity was granted and the aforesaid plea is not even dealt with by the Adjudicating Authority. As far as the Tribunal is concerned, we find that rejection of this plea is totally untenable. The Tribunal has simply stated that cross examination of the said dealers could not have brought out any material which would not be in possession of the appellant themselves to explain as to why their ex factory prices remain static. It was not for the Tribunal to have guesswork as to for what purposes the appellant wanted to cross examine those dealers and what extraction the appellant wanted from them." 12. There are several other judgments suggesting that, if the department wishes to rely on statement of witnesses cross-examination, when asked for, should be granted. The Courts in the past in the context of departmental proceedings had made room for exceptions. But the recent judicial trend suggests virtual elimination of such exceptions. In this case, we are not required to trace all such judgments. We may proceed on the basis that if the petitioners had asked for cross examination of witnesses in time the Commissioner was required to grant the same as the department was relying on the statements. 13. In this context, we are not able to accept the suggestion of the counsel for the department that the petitioners had not asked for such cross-examination or that, at any rate, the same was asked at a belated stage. We have noted that, as far back as on 05.01.2015, the petitioners had taken up the issue of cross-examination of Shri S.C. Shah before his statement could be relied upon. Further, the petitioners had approached this Court in Special Civil Application No. 6837 of 2016 complaining about the Settlement Commission proceeding further with the hearing without offering cross-examination. The Court, on 26.04.2016, relegated the petitioners back to the Settlement Commission permitting to holding the petitions premature. Yet again on 14.05.2016, the petitioners made a detailed application before the Settlement Commission and urged that the statements of Shri S.C. Shah and others have been recorded behind the back of the petitioners. They are cited as departmental witnesses. The statements are being used against the petitioners to establish the allegation of accommodation entries. The department, in the report under Rule 9, had referred to 26 other witnesses in addition to Shri S.C. Shah. They are cited as departmental witnesses. The statements are being used against the petitioners to establish the allegation of accommodation entries. The department, in the report under Rule 9, had referred to 26 other witnesses in addition to Shri S.C. Shah. The petitioners, therefore, requested as under: "The Applicants have to state that the statement of aforesaid persons being departmental witnesses recorded behind the back of aforesaid applicants have been used by Pr. CIT (Central) Ahmedabad against the applicants directly or indirectly for making allegation of accommodation entries, hence under the principle of Natural Justice and equity Cross examination of the aforesaid persons are required to be granted." 14. These facts would clearly demonstrate that the petitioners, from the outset, were keen on cross-examining of Shri S.C. Shah and other witnesses whose statements were relied upon by the department. 15. The fact, that the department did rely on such statements, is not possible to nor disputed. A report under Rule 9 and the reference made by the Settlement Commission in its impugned order to such statements would conclusively prove that insofar as the relation of the petitioner-company to Shri S.C. Shah and other related person is concerned, these statements did form part of important materials. That being the case, in absence of any clear discerning line of reasons adopted by the Settlement Commission, it would not be possible to segregate the effect of these statements from the rest of the material. This is in context of the department's contention before us that over and above the statements of witnesses, there was sufficient other evidence produced by the department to establish the case of mis-disclosures by the petitioners in connection with transactions with S.C. Shah related companies. In absence of the statements of witnesses whether the Settlement Commission would have accepted such material or not, is therefore not possible to judge. 16. Regarding additional material being produced by the department at a late stage, we may recall, the facts are that the hearing was going on in first week of May 2015. The department, on 10.05.2015, produced a DVD containing 1540 pages which, in turn, contained entries pertaining to two companies Praneta Industries Ltd. and Chandani Textile Engineering Ltd. The next date of hearing fixed by the Settlement Commission was 12.05.2015. It is perhaps possible to see the inconvenience caused to the petitioners in the process. The department, on 10.05.2015, produced a DVD containing 1540 pages which, in turn, contained entries pertaining to two companies Praneta Industries Ltd. and Chandani Textile Engineering Ltd. The next date of hearing fixed by the Settlement Commission was 12.05.2015. It is perhaps possible to see the inconvenience caused to the petitioners in the process. However, when, as pointed out by the Revenue, these pages only contained entries which were produced to relate various transactions concerning the petitioners and Shri S.C. Shah and other persons, perhaps the time of two days may not be seen as short as it otherwise appears. We may note, the proceedings were getting time barred on 31.05.2015. 17. This issue, however, pales into insignificance because it relates to the very same transactions to which, the question of cross-examination of Shri S.C. Shah and other witnesses relates. Since we have already held that it is not possible to separate the Settlement Commission's finding on the question of these issues, by eliminating the effect of the statements of witnesses, whether the petitioners had sufficient time to meet with the additional material produced in form of the DVD would have no effect. 18. This brings us to the Revenue's contention whether despite such findings can we save the order of Settlement Commission? We have recorded the concluding portion of the Settlement Commission's order which is preceded by a lengthy recording of the materials on record and the rival contentions. The Settlement Commission essentially, on four grounds came to the conclusion that the petitioners had not made true and full disclosures. Undisputedly, sub paras 1 and 4 of para 30 of the conclusion portion of the order of the Settlement Commission is relatable to the statements of witnesses relied upon by the department without cross examination. However, undisputably, sub paras 2 and 3 of the same relates to entirely independent and unconnected transactions. In para 2, the Settlement Commission came to the conclusion that applicant i.e. the present petitioner had disclosed an income of Rs. 17.79 lacs at the rate of 7 paise per Rs. 100/- on an unaccounted trade in commodities which was estimated at Rs. 2134 crores. The Settlement Commission was of the opinion that the applicant had not given any evidence about actual trade, its quantum and the capital employed for such a huge turnover. The rate of brokerage claimed was also meager. 100/- on an unaccounted trade in commodities which was estimated at Rs. 2134 crores. The Settlement Commission was of the opinion that the applicant had not given any evidence about actual trade, its quantum and the capital employed for such a huge turnover. The rate of brokerage claimed was also meager. In similar trade, the rate is upto Rs. 2 per Rs. 100/-. At such rate, the income could be estimated at Rs. 42 crores. On basis of such findings and conclusions, the Settlement Commission held that the applicant had not disclosed true and full facts of the trade and the income earned. 19. Likewise, in sub para 3, the Settlement Commission noted that the applicant had disclosed a sum of Rs. 25.41 lacs at the rate of Rs. 2/- per Rs. 100/- in other commodity trade of castor. This involves a turnover of more than Rs. 12.50 crores. The applicant had not given any evidence about the actual trade, its quantum and capital employed for such a huge turnover. The Commission, therefore, concluded that the applicant had not given true and full facts of the trade and the income earned. 20. These findings of the Settlement Commission are in the realm of assessment of evidence on record and essentially factual in nature. This Court in case of in case of Saurashtra Cement Ltd. And ors. v. Commissioner of Customs and anr. reported in 2012(3) G.L.H. 235 , examined scope of judicial review by the Supreme Court against the order of Settlement Commission in light of various decisions of the Apex Court and following observations were made: "15. It is well settled that no finality clause in a statute would oust the jurisdiction of the High Court under Article 226 of the Constitution or that of the Supreme court under Article 32 or 136 of the Constitution. Nevertheless, the parameters of judicial intervention in a decision rendered by an administrative tribunal are well recognised and well laid down. Ordinarily, the court would interfere if the Tribunal has acted without jurisdiction or failed to exercise jurisdiction vested in it or the decision of the Tribunal is wholly arbitrary or perverse or mala fide or is against the principles of natural justice or when such decision is ultra vires the Act or the same is based on irrelevant considerations. 16. Ordinarily, the court would interfere if the Tribunal has acted without jurisdiction or failed to exercise jurisdiction vested in it or the decision of the Tribunal is wholly arbitrary or perverse or mala fide or is against the principles of natural justice or when such decision is ultra vires the Act or the same is based on irrelevant considerations. 16. When examining the scope of judicial review in relation to a decision of Settlement Commission, we must further bear in mind that the Settlement Commission is set up under the statute for settlement of revenue claims. Its decision is given finality and it also has power to grant immunity from prosecution, of course, subject to satisfaction of certain conditions. The scope of court's inquiry against the decision of the Settlement Commission, therefore, is necessarily very narrow. The Apex Court in the case of State of U.P. And Another v. Johri Mal reported in (2004) 4 SCC 714 observed that the scope and extent of power of judicial review of the High Court under Article 226 of the Constitution of India would vary from case to case, the nature of the order, the relevant statute as also other relevant factors including the nature of power exercised by the public authorities, namely, whether the power is statutory, quasi-judicial or administrative. It was observed that the power of judicial review is not intended to assume a supervisory role. The power is not intended either to review governance under the rule of law nor for the courts to step into the areas exclusively reserved by the suprema lex to the other organs of the State. The court observed that the limited scope of judicial review is – (i) Courts, while exercising the power of judicial review, do not sit in appeal over the decisions of administrative bodies; (ii) A petition for a judicial review would lie only on certain well-defined grounds (iii) An order passed by an administrative authority exercising discretion vested in it, cannot be interfered in judicial review unless it is shown that exercise of discretion itself is perverse or illegal. (iv) A mere wrong decision without anything more is not enough to attract the power of judicial review; the supervisory jurisdiction conferred on a Court is limited to seeing that the Tribunal functions within the limits of its authority and that its decisions do not occasion miscarriage of justice. (iv) A mere wrong decision without anything more is not enough to attract the power of judicial review; the supervisory jurisdiction conferred on a Court is limited to seeing that the Tribunal functions within the limits of its authority and that its decisions do not occasion miscarriage of justice. (v) The courts cannot be called upon to undertake the government duties and functions. The court shall not ordinarily interfere with a policy decision of the State. Social and economic belief of a judge should not be invoked as a substitute for the judgment of the legislative bodies. (See Ira Munn v. State of Illinois.) 17. Despite such narrow confines of judicial review of the decision of the Settlement Commission, it is undeniable that the jurisdiction under Article 226 of the Constitution is not totally ousted. In a given situation if the Settlement Commission has taken into consideration irrelevant facts and such consideration has gone into its decision-making process resulting into grave injustice and prejudice to the party then within the narrow confines of the judicial review, interference would still be open." 21. Objection regarding non-verification of records does not seem to have been taken during the settlement proceedings and in any case, would not go to the root of the matter being a procedural matter. 22. We, therefore, do not find any scope for interference. All the petitions are, therefore, dismissed. 23. Before closing, however, we accept the suggestion of the counsel for the petitioners that the Settlement Commission has made certain observations more in the nature of directives to the Assessing Officer to make assessments in particular manner as can be seen in the above noted sub paras 1 to 4 of para 30 of the Settlement Commission's order. Such directions are, therefore, deleted.