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Facts
The assessee filed eighteen appeals challenging orders from the Learned Commissioner of Income Tax. During the proceedings, the assessee opted for the Direct Tax Vivad-se-Vishwas Scheme, 2024, and sought to withdraw all appeals after complying with the scheme's requirements (filing Form-1 and receiving Form-2).
Held
The Tribunal permitted the withdrawal of all eighteen appeals and consequently dismissed them. It was clarified that the assessee is at liberty to approach the Tribunal again if any prejudice arises from the settlement under the Vivad-se-Vishwas Scheme.
Key Issues
Whether appeals filed before the Income Tax Appellate Tribunal can be withdrawn and dismissed when the assessee opts for the Direct Tax Vivad-se-Vishwas Scheme, 2024.
Sections Cited
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Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI
Before: SHRI SS VISWANETHRA RAVI & SHRI JAGADISH
आदेश / O R D E R PER BENCH:
Aforesaid eighteen appeals filed by the assessee arising out of the orders of Learned Commissioner of Income Tax (NFAC), Delhi dated 11.11.2024. to 3411/Chny/2024 :- 2 -:
The Ld. Authorized Representative (A.R) of the assessee, at the outset stated that assessee has opted for Direct Tax Vivad-se-Vishwas Scheme, 2024 in the above appeals and therefore, wants to withdraw the appeals. The Ld. A.R has submitted a copy of Form-1 filed by the assessee and Form-2 issued by the designated authority in support of its contention.
We have heard both the sides, and perused the materials available on record. In these cases, the assessee has opted for the Direct Tax Vivad-se-Vishwas Scheme, 2024 in the above appeals by filing Form-1. The Designated Authority has also issued Form No.2 for the settlement of pending tax dispute. The Ld. AR has now made a request to withdraw the appeals. Accordingly, the appeals are permitted to be withdrawn and therefore, dismissed. However, it is open to the assessee to approach the Tribunal by filing an appropriate application in the event of any prejudice caused in respect of the settlement of tax dispute under the Direct Tax Vivad-se-Vishwas Scheme, 2024. to 3411/Chny/2024 :- 3 -:
In the result, all the appeals filed by the assessee are dismissed as withdrawn.
Order pronounced in the open Court on 11th April, 2025.