Allowing the petition the Court held that there was no true and full disclosure of additional income in the application filed by ML under section 245C. There was a vast difference between the amount disclosed in the application and the amount finally determined by the Settlement Commission. The Settlement Commission had not only taken up the task of an adjudicating authority but had also failed to note that ML had not made a true and full disclosure of the income which had not been disclosed before the Assessing Officer.  The Settlement Commission ought to have rejected the applications because the intention of the assessees was only to take a chance by not disclosing truly and fully the correct additional income which was not disclosed at the time of filing of original returns under section 139 and to take advantage of the limited scope of enquiry in the proceedings before the Settlement Commission. The orders passed under section 245D(4) by the Settlement Commission were quashed. Applied Ajmera Housing Corporation v. CIT (2010)  326 ITR 642 (SC)  (AY.2003-04 to 2008-09) (W.P.No.2417 dt. 27-5-2021)