R. JAYASIMHA BABU, J.

A right to be dishonest is the right that is asserted by the petitioner herein. It is his contention that the Settlement Commission has a duty to entertain the offer made by the petitioner even if found to be falling short of full and true disclosure required of an applicant under section 245C of the Income-tax Act, 1961 (hereinafter referred to as "the Act") and not to reject the same under section 245D(1) of the Act The petitioner set up a factory near Coimbatore for the manufacture of synthetic gems. He promoted a private limited company for that purpose. The shares of that company are held by the petitioner, his wife and daughter. The total investment made is Rs. 75.5 lakhs. The only source from which that investment was made was claimed by the assessee to be income derived from agriculture and dairy farming by himself, his wife and daughter. He claimed that besides 15 acres of agricultural lands owned by his wife, she had taken on lease 100 acres of land and had derived substantial income therefrom. It is not in dispute that the petitioner, his wife and his daughter are not assessees under the Agricultural Income-tax Act of the State and there