JUDGMENT judgment of court was delivered by S. Ravindra Bhat J.-In these three appeals, Revenue urges that common order of Income-tax Appellate Tribunal in IT(SS) Nos. 29 to 32/D/2011 covering block period April 1, 1995, to October 5, 2001, is erroneous in so far as it upheld cancellation of interest added under section 245D(2C) of Income-tax Act, 1961. search took place in premises of one K. C. group on October 5, 2001. Besides cash to extent of Rs. 2,16,500 and stock to tune of Rs. 53,21,218, certain documents and books of account were seized. Notice under section 158BC was served on assessee on October 8, 2002; responding to it assessees filed returns for block period ending October 5, 2001, on December 10, 2002, disclosing nil income. Soon, thereafter, on December 11, 2002, they applied under section 245D(1) to Settlement Commission and disclosed Rs. 10 lakhs in hands of each of four persons, i.e., total of Rs. 40 lakhs at 2 per cent. of turnover of Rs. 20 crores. By speaking order, these applications were admitted under section 245D(1) on October 23, 2003. Settlement Commission called for report under rule 9 read with section 245D(1) from Commissioner of Income-tax. matter was heard on several dates and finally order was made on March 26, 2010. final order directed Revenue to accept offer of additional income of Rs. 1,48,16,160 referred to in body of Settlement Commission's order. Settlement Commission rejected waiver of interest under various provisions of Act. Consequently, interest under section 220(2) in terms of section 245D(2C) was directed to be recovered. While computing amounts payable, Assessing Officer passed in his consequential order dated May 4, 2010, Rs. 13,03,211 as interest recoverable for period between January 1, 2004, and March 26, 2010. This addition was appealed to Commissioner of Income- tax (Appeals) as untenable. Commissioner of Income-tax (Appeals) took note of dates when these amounts were offered-soon after admission of application before Settlement Commission and also date on which deposit was made pursuant to final order which was on May 4, 2010. This is to be found in following chart, prepared by Commissioner of Incometax (Appeals). said chart is extracted below: 11-12- Date of filing of application under section 245C(1) 2002 23-10- Date of admission of application under section 245D(1) 2003 Undisclosed income declared as per order under Rs. section 245D(1) dated 23-10-2003 10,00,000 Due date of payment of tax 1-1-2004 26-12- Date on which tax has been deposited by appellant 2003 Tax paid by appellant in pursuance of order under Rs. section 245D(1) 6,12,000 Additional tax paid as on 24-7-2007 Rs. 12,240 Date of passing of order under section 245D(4) 26-3-2010 Rs. Undisclosed Income finally settled 37,04,040 Balance tax paid by appellant in response to order Rs. passed by Settlement Commission under section 16,43,000 245D(4) Date on which tax has been paid by appellant in 4-5-2010 pursuance of order 245D(4) In view of these facts, Commissioner of Income-tax (Appeals) returned finding that assessee had deposited tax within time specified under section 245D(2A). Commissioner of Income-tax (Appeals) also observed that, however, Assessing Officer, while passing order under section 158BC read with 245D(4) of Act, charged interest under 245D(2C) of Act for period starting from January 1, 2004, to March 26, 2010, at 15 per cent. amounting to Rs. 13,03,211 without appreciating that section 245D(2C) of Act can be invoked only if assessee does not deposit income-tax payable on income disclosed and admitted under section 245D(1) of Act. In instant case, appellant deposited Rs. 6,12,000 within time prescribed under section 245D(2C) on income of Rs. 10 lakhs as per order under section 245D(1) in view of admission. It is thus apparent that there were clear findings rendered by Commissioner of Income-tax (Appeals) with respect to error in calculation of interest payable, as per Assessing Officer's determination. Income-tax Appellate Tribunal has, in its decision, elaborately considered provisions of Chapter XIX-A more particularly scope of Settlement Commission's jurisdiction. It also took into consideration several authorities as well as judgment of Supreme Court in Ajmera Housing Corporation v. CIT [2010] 326 ITR 642 (SC); [2010] 234 CTR (SC) 118. Income-tax Appellate Tribunal, thereafter, concluded as follows: "... In view of foregoing, especially when Revenue did not place any material before us controverting aforesaid findings of learned Commissioner of Income-tax (Appeals) nor referred us to any contrary decision, so as to enable us to take different view in matter, we are not inclined to interfere. Therefore, grounds Nos. 1 and 2 in appeal are dismissed." Counsel for Revenue argued that decisions of Commissioner of Income-tax (Appeals) and Income-tax Appellate Tribunal are erroneous and submitted that Assessing Officer's decision to direct payment of Rs. 13,03,211 as interest was justified. Revenue also submits that decision in Ajmera Housing Corporation (supra) was inapt in circumstances of case. We notice that question of levying any additional interest over and above what is permissible under Chapter XIX-A would not arise in given circumstances of case. Concededly at time when application was filed before Settlement Commission, assessee deposited admitted tax liability. Soon, thereafter, when application was admitted, amount required was deposited within time stipulated under section 245D(6A). further tax liability determined was payable after final decision. records and materials examined by Commissioner of Income-tax (Appeals) and upheld by Income-tax Appellate Tribunal disclose that even tax liability finally determined was satisfied. In these circumstances, addition of interest for period during pendency of application before Settlement Commission was entirely unwarranted. We do not see any reason to disturb concurrent findings of fact. appeals do not raise any substantial question of law and are, consequently, dismissed. *** Commissioner of Income-tax v. Vishan Da