The Assessee/Applicant filed an application before the Settlement Commission, disclosing certain additions not reported in the return of income. The Settlement Commission made an addition towards share capital, noting that it was derived from individuals who either did not exist or were identified as accommodation entry operators. The assessee failed to provide substantial evidence to substantiate the authenticity of the share capital. Further, the assessee did not disclose the additional income towards share capital at the threshold stage of the settlement application. Despite these shortcomings, the Settlement Commission allowed the application, made the additions on share capital, and granted immunity from penalty and prosecution. The Revenue challenged this decision, arguing that the application lacked full and true disclosure, a prerequisite for the Settlement Commission to assume jurisdiction.  The High Court observed that if an application lacks full and true disclosure, the Settlement Commission loses jurisdiction to entertain such applications or grants immunity from penalty and prosecution. The High Court set aside the order of the Settlement Commission, citing the Supreme Court’s decision in the case of Ajmera Housing. The Hon’ble Supreme Court dismissed the Special Leave Petition filed by the assessee, upholding the High Court’s decision. (AY.  2001-02 to 2007-08)