Dismissing the petition of the revenue, the Court held that additional offer in addition to accepted liability, cannot be termed as non -disclosure of full and true facts in application u/s. 245C of the Act. Order of settlement commission is affirmed.Order of settlement commission is affirmed . referred Ajmera Housing Corporation v CIT ( 2010) 326 ITR 642 (SC) , PCIT v Shree Nilkanth Developers ( 2017) 8 ITR -OL. 32 (Guj) (HC ). (AY. 2004 -05)