Section 245C of the Income Tax Act, 1961 — Settlement of cases — Settlement Commission after considering the material on record had given a finding of fact to the effect that there was full and true disclosure made by the assessees and that there was no willful attempt to conceal material facts and if for the reason that issues which pertained to past periods could not be reconciled due to lack of further evidence, the assessees with a view to bring about a settlement, agreed to pay higher amount as proposed by the revenue, it certainly could not be termed as revision of the original disclosure made under section 245C inasmuch as, there was no further disclosure but an acceptance of additional liability based on the disclosure already made before the Settelement commission— Principal Commissioner of income tax vs. ITSC [2020] 420 ITR 149 (Gujarat)