Allowing the appeal of the Revenue against the order of single judge ,the Court held that , this was not a case in which the assessee had merely accepted the additions suggested by the Commission, to settle the matter once and for all times. At the first stage, even before the assessee was directed to sit along with the Assessing Officer and the Officer of the Commission to reconcile the differences, which led to the suggestions on behalf of the Commission, a disclosure of further income was made, which was not available in the original application made under section 245C . This led to a definite conclusion that there was no full and true disclosure of the undisclosed income and the source from which it was derived in the application filed under section 245C . The Settlement Commission ought not to have proceeded with the application when the assessee made a voluntary offer of additional income, when the application was pending, in addition to that disclosed in its application under section 245C . Court also held that ,Considering the long pendency of the matter before the Settlement Commission and before the court, the court permitted the assessee to file an appeal from the assessment order within thirty days from the date of receipt of a copy of the judgment of the court in the writ appeal. Decision of single judge was set aside . (WP.No. dt 11-02 2019)