The application must be made after a show cause notice has been issued under Section 28 or Section 28A but before the adjudicating authority passes a final order. This window — post-SCN, pre-adjudication order — is the only period during which the Settlement Commission has jurisdiction. CBLE tests this timing window precisely since both early applications (before SCN) and late applications (after adjudication order) are outside the Commission's jurisdiction.

Settlement is a voluntary disclosure mechanism — the applicant admits liability, discloses the true extent of duty evasion, and pays the determined amount in exchange for potential immunity from prosecution and penalty. Appeal is a right-based challenge to an adjudication order on grounds of law or fact. Settlement is available pre-adjudication; appeal is available post-adjudication. The finality of a settlement order — which cannot be appealed — is the most important structural difference between the two routes. CBLE tests this distinction frequently.

Yes. Immunity may be withdrawn under Section 127H where it is subsequently found that the applicant had concealed material facts, had given false evidence, or had failed to cooperate with the Commission. Upon withdrawal of immunity, the applicant becomes liable for prosecution and penalty as if immunity had never been granted. The conditions for immunity and the grounds for withdrawal are treated as paired CBLE concepts.

The Central Board of Indirect Taxes and Customs (CBIC) replaced the commission with temporary bodies called "Interim Boards for Settlement". These boards only process applications that were submitted before April 1, 2025 - Interim Board I (Delhi)Interim Board II (Kolkata)Interim Board III (Mumbai)Interim Board IV (Chennai, located near you)