Please read the following case study and answer the question accordingly

The Settiement Commission is meant for providing a chance to the tax evader who wants to turn a new leaf, as recommended by the Direct Taxes Inquiry Committee, popularly known as the Wanchoo Committee. To achieve this objective, the Commission, so constituted, was empowered to grant partial or full waiver from imposition of penalty and interest and so also grant immunity from prosecution so as to lure the tax evader to \"come clean\". Settlement Commission for Customs & Central Excise has continued to serve this purpose of an alternative channel for resolution of disputes. The law makers, probably having taken the cue from Income Tax Act, 1961, stipulated certain conditions relating to ling of an application for settlement of cases in Customs and Excise, thereby restricting the scope of operation of the said machinery. Section 127B of the Customs Act is parimateria with Section 2450 of the Income Tax, 1961. Section 127B of the Customs Act, 1962 provides ling of application by the applicant for settlement of cases before the Settlement Commission. Accordingly, the Settlement Commission cannot entertain cases which are pending with the Appellate Tribunal or in a Court. Similarly, the matters relating to classication cannot be raised before the Commission. It is also specified that no application can be made unless the appellant has led a bill of entry or a shipping bill etc or unless the appellant has received a show cause notice issued by the proper Ofcer and the additional amount of duty accepted as payable by the applicant in his application exceeds two lakh rupees. '- Such restrictions and many others borne out of interpretation of the statute- invariably lead to interpretation of the wordings thereof and eventually to litigation. One may say, that as law evolves out of such interpretation and given the nascent stage of the provisions related to the said machinery, such issues would denitely have been unavoidable. Accordingly, in the short span, the Settlement Commission has also been besotted with certain teething issues, which have since been 'settled