Dismissing the appeal of the revenue the Court held that  the in order to decide whether a contract was a composite contract or separate contracts, a deeper probe into the factual scenario as well as the legal position was required. If such was the fact situation in the case on hand, the application of the assessee could not have been declared invalid on account of failure to fully and truly disclose its income. Thus, what was required to be done by the Commission was to allow the application to be proceeded with under section 245D(2C) and take up the matter for consideration under section 245D(4) and take a decision after adjudicating the claim The issues which were requested to be settled by the assessee before the Commission, qua, the report of the Commissioner could not obviously be an issue for a prima facie decision at the sub-section (2C) stage. The rejection of the application for settlement of case was not justified.( AY.2015-16 to 2018-19)