Returns of income had been filed by the assessee in respect of assessment years 2015-16, 2016-17, 2017-18 and 2018-19 offering to tax the income from onshore supply and services only. While assessment proceedings were pending the assessee applied for settlement of the case. The Settlement Commission held that the contract was composite and indivisible and hence the applicant, i. e., the assessee, had failed to make a full and true disclosure of income. On a writ petition against the order the Court held that  the assessee had just applied for settlement of the case. The Commission however, in considering the “validity” or otherwise of the application proceeded to delve into the merits of the matter even at that stage. The order of the Settlement Commission was beyond the scope of S.  245D(2C) having been passed on the merits of the issue raised.( AY.2015-16 to 2018-19)