Full and true disclosure in settlement proceedings is essential; repeated revisions can justify rejection of the application.

Settlement proceedings require full and true disclosure at the outset, and repeated revisions or inconsistent stands on the existence of an AOP, the quantum of undisclosed income, and its source justify rejection of the application. The Court applied the settled rule that judicial review over the Settlement Commission's order is narrow and interference lies only for mala fides, breach of natural justice, or patent illegality. The finding that the AOP was non-existent was treated as a factual conclusion not shown to be perverse, so the rejection of settlement was upheld and no interference was called for.

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Issues: Whether the Settlement Commission's rejection of the settlement application for the assessment years in question, on the ground of absence of true and full disclosure and repeated revision of the disclosed income, called for interference.

Analysis: The application for settlement was found to rest on shifting and inconsistent stands regarding the existence of an AOP and the quantum and source of undisclosed income. The materials recorded by the Settlement Commission showed that the petitioner repeatedly revised the disclosures during the proceedings, and the Court held that such conduct undermined the requirement of full and true disclosure at the threshold. The Court also applied the settled principle that judicial review over an order of the Settlement Commission is narrow and interference is warranted only in cases of mala fides, violation of natural justice, or patent illegality. The finding that the AOP was non-existent was treated as a factual conclusion not shown to be perverse.

Conclusion: The rejection of the settlement application was upheld and no interference was called for.

Final Conclusion: The writ petition failed, as the Court sustained the Settlement Commission's view that the settlement disclosures were neither true nor full and that the repeated revisions justified rejection of the settlement request.

Ratio Decidendi: In settlement proceedings, full and true disclosure must be made at the outset, and repeated revisions or inconsistent disclosures justify rejection of the application, especially when the Commission's factual findings are not shown to be perverse.

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