Held allowing the appeal,the Court held that  the since the case pertained to the period prior to the abolition of the scheme of settlement under section 245C, the provisions contained in section 245C were applicable. The provisions contained in section 245C(1) stated that a prayer for settlement could be made giving full and true disclosure of income which had not been disclosed, the manner in which such income had been derived, the additional amount of tax payable on such income and other particulars prescribed, applied. The application itself titles “Confidential Enclosure ‘D’: The manner in which the additional income has been derived”. Such application contained the details of the assessee’s involvement in inflating refinery loss, the process of refinery, as to how the loss was being assumed and periodically accumulated had been explained and the assessee had submitted the details of the manner in which the undisclosed income, of Rs. 80 crores was derived. According to the assessee, the stock-in-trade was directly related to Rs. 80 crores which in turn was a result of inflation of refinery loss, which perhaps the assessee was not correct in claiming as such, and this appears to be only a device not to disclose an income which the assessee otherwise had accumulated. Such aspect was not considered in a proper manner by the competent authority in the order passed by the authority rejecting the application under section 245C on the ground that full and true particulars of the materials and evidence had not been disclosed with regard to the manner in which the undisclosed income of Rs. 80 crores was derived. Since the rejection of the application for settlement had not only resulted in imposition of interest, penalty, but also in prosecution, the competent authority was required to closely examine and scrutinise the manner in which the undisclosed income was derived, as was stated by the assessee in his application. The matter was remanded to the competent authority to scrutinise in detail the manner in which the assessee had derived undisclosed income of Rs. 80 crores. Even according to the Revenue, as far as the remaining Rs. 70 crores was concerned, the assessee was already eligible for settlement. In the writ petition the court had proceeded to accept the reasoning given by the authority resulting in dismissal of the writ petition. The order passed dismissing the writ petition was set aside. Consequently, the order passed by the competent authority rejecting the application for settlement under section 245C was also set aside. The case is remanded to the competent authority for consideration afresh of the writ petitioner’s application for settlement.(AY. 2011-12 to 2017-18)