(1) Notwithstanding anything contained in any provision of this Act, where an agreement is reached, under sub-section (9) of section 304, it shall be binding on both the parties and it cannot be challenged in any authority, Tribunal or Court either by the assessee or any other income-tax authority.

(2) Every agreement, concluded under section 304 shall be conclusive as to the matters stated therein and any matter not covered by such agreement shall be reopened in any proceeding under this Act.