Income initially disclosed before SetCom couldn't be said to be concealed if additions were made due

IT: Normally, income offered for tax in an application for settlement would bind parties concerned and any revision thereof, would prima facie, be evidence of original application for settlement not declaring full income, however in a case where correct determination of income is dependant upon application of appropriate transfer pricing rule which to an extent is subjective, if an additional income is declared during course of hearing in view of what emerges during debate before Commission, it