The petitioner has filed this writ petition challenging the order dated 16.02.2018 of the 1st respondent, viz., Income Tax Settlement Commission refund of Rs. 98,18,350/-, vide cheque dated 25.10.2016, has already been issued to the petitioner for the assessment year 2016-17 by the CPC, Bengaluru after processing the original return filed by the petitioner and thus, there exists no refund due for the assessment year 2016-17, which can be adjusted against the additional tax liability. The report states that the petitioner has offered additional income of Rs. 1,83,68,000/- before the Settlement Commission for the assessment year 2016-17, which resulted in additional tax liability of Rs. 63,56,798/-, however, the petitioner has not paid any tax on the additional income offered for the assessment year 2016-17. Hence, it was reported that the petitioner has not paid the tax in full for the additional income offered before the Settlement Commission, therefore, cannot be said to have fulfilled the condition and requested the Commission to declare the application as invalid. he Settlement Commission having been held to be a Tribunal, the petitioner is entitled to seek judicial review of the order of the Settlement Commission in a petition under Article 226 of the Constitution of India. It is to be borne in mind that the Settlement Commission was constituted for settling complicated claims of tax evaders as an extraordinary measure for giving an opportunity to such persons to make a confession and have the matters settled once for all and purchase peace. Thus, the Settlement Commission is a forum before which the assessee surrenders himself and it is not a forum for challenging the legality of assessment order or other orders passed in any proceedings under the Act. The Scheme of the Act clearly shows that the power conferred on the Settlement Commission is wide, as it has the power to give immunity against prosecution or imposition of penalty.. For the above reasons, this court is of the view that the petitioner should be permitted to proceed further and for which purpose the petitioner should be given an opportunity to pay the tax.