Revenue challenged the order of Settlement Commission passed under S.  245D(2C) on ground that Settlement Commission did not pass an order under section 245D(3) requiring a further enquiry into certain transactions of assessee which were admittedly bogus before passing said order under section 245D(2C).  Dismissing the petition of revenue the Court held that order u/s. 245D(3), it is a discretion of Settlement Commission after calling for and examination of records, to require Commissioner to make further enquiry/investigation if Settlement Commission is of opinion that any further enquiry or investigation in matter is necessary and it is not necessary for Settlement Commission to pass a formal order under section 245D(3). Insistence of department, to Settlement Commission to pass a formal order under section 245D(3) before proceeding further to stage of section 245D(4) was not valid.  Since department had not set out grounds and reasons that why in facts of case, such enquiry or investigation as envisaged under section 245D(3) was necessary and, further, Settlement Commission adverted to material on record and came to conclusion that there was no failure of full and true disclosure order passed by Commission under S. 245D(2C) is  justified and up held. (WP No. 1788 of 2018 dt. 4-04-2019) (AY. 2008-09 to 2015-16)