Assessee filed an application under section 245C before Settlement Commission.Settlement Commission passed an order granting immunity from prosecution and penalty to assessee.High Court opined that mere recording of satisfaction by Settlement Commission, by itself, would not be sufficient to satisfy conditions under section 245H(1) and assessee had to be honest and fairly disclose complete undisclosed income in first instance before Settlement Commission and couldnot make disclosures in installments in a settlement proceeding. Accordingly, High Court held that since there was no foundation for finding of Settlement Commission that there was full and fair disclosure, matter was to be remanded for reconsideration as to whether immunity from penalty and prosecution ought to be granted or not.  SLP filed by assessee against impugned order of High Court was  dismissed.