As per the case facts an assessee a banking and leasing company filed an application before the Income Tax Settlement Commission for settlement of its tax liabilities including immunity from ... penalty and prosecution The Settlement Commission granted certain relief which was then challenged by the revenue The High Court remanded the matter back to the Settlement Commission to determine the immunity from penalty and prosecution afresh The bank appealed this decision to the Supreme Court The question arose whether the High Court was correct in interfering with the Settlement Commission's reasoned order and remanding the matter for a fresh determination of immunity from penalty and prosecution Finally the Supreme Court allowed the appeal and set aside the High Court's judgment restoring the Settlement Commission's original order The Court stated that an order or proceeding of a Settlement Commission should not be scrutinized by the High Court as an appellate court It emphasized that unsettling reasoned orders of the Settlement Commission could erode confidence and lead to more litigation where settlement is possible highlighting the need to consider this larger picture