Section 245C and 245D of the Income Tax Act, 1961 — Settlement Commission — Proceedings before the Settlement Commission are in the nature of settlement between the parties and are not strictly speaking adjudicatory proceedings. The fact that the applicants have offered to pay amounts, the liability whereof has not been accepted by them, cannot be termed as non-disclosure of full and true facts in the applications under section 245C, applicants have not made any revised disclosures, nor have they accepted the liability to pay the additional amounts, nonetheless, in the spirit of settlement, the applicants have, offered to pay such amounts to bring a quietus to the matter and buy peace of mind, moreover, the additional amounts which the applicants have agreed to pay are meagre considering the overall amounts disclosed in the applications under section 245C(1), under the circumstances, the contention that there was no full and true disclosure in the applications made under section 245C(1) does not merit acceptance—  PR. CIT vs. Shreyansh Corporation [2020] 421 ITR 153 (GUJ)