Allowing the petition of the revenue the Court held that the statement was made voluntarily on January 20, 2012, in the course of search proceedings. There is a presumptive value to such statement by virtue of section 132(4) of the Act. Moreover, it is not merely the statement that is material in the present case; in fact ledgers and other books of account were seized. The approach of the Settlement Commission was flawed throughout. Apart from brushing aside the fact that the retraction took place close to two years after the statement was made, the Commission overlooked that nowhere did the assessees complain that the statement of the first respondent was recorded under coercion. The second and equally important reason to hold that the Settlement Commission gravely erred in its approach was because of utter disregard to the condition that the assessee always has the duty to make a full disclosure. After brushing aside the Revenue’s objections with regard to the complete lack of explanation by the assessee with respect to credits claimed, the Settlement Commission proceeded to compute the amounts offered and observed that the difference between the net asset and the income declared was Rs. 5.55 crores. J accepted the difference as their undisclosed income. Clearly, the decision of the Settlement Commission was untenable in law. Once the assessee approached it with a certain amount, representing that it constituted full and true disclosure (and had maintained that to be the correct amount till the date of hearing) the question of “offering” another higher amount as a “full” disclosure was impermissible. The amount offered in this case, clearly could not have been considered or accepted. The Settlement Commission, in this regard erred as there was no full and true disclosure by the assessees. Consequently, the order was to be set aside and quashed. (AY. 2006-07 to 2013-14)