Dismissing the petition of the revenue the Court held that the Settlement Commission accepted the offer. When compared to the disclosure made by the assessee to the tune of Rs. 11,33,02,651 in the application filed before the Settlement Commission the grievance made by the Department with regard to the amount of Rs. 2,04,88,560, was marginal. Accordingly, when the assessee had agreed for addition of Rs.1,02,44,280 to put quietus to the issue and to settle the matter, the Settlement Commission had accepted the assessee’s offer. This was justified. The order under section 245D was valid.( AY.2010-11)