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Facts
The assessee filed an appeal against the CIT(A) order for Assessment Year 2013-14. During the proceedings, the appellant opted for the Vivad Se Vishwas Scheme, 2016, completing all statutory formalities and depositing the requisite taxes. The Revenue accepted the declaration and issued Form-4, confirming the final settlement of the dispute.
Held
The Tribunal acknowledged that the dispute has been fully and finally settled under the Vivad Se Vishwas Scheme, 2016, as evidenced by Form-4 issued by the Revenue. Consequently, it held that nothing survives for adjudication in the appeal, rendering it non-maintainable and infructuous.
Key Issues
Whether the income tax appeal becomes infructuous and non-maintainable after the assessee opts for and successfully settles the dispute under the Vivad Se Vishwas Scheme, 2016.
Sections Cited
Vivad Se Vishwas Scheme, 2016
AI-generated summary — verify with the full judgment below
Order PER LALIET KUMAR, J.M: This is an appeal filed by the Assessee against the order of the Ld. CIT(A)/NFAC, Delhi dt. 11/07/2024 for the Assessment Year 2013-14. 2. At the outset, the learned Authorised Representative (AR) submitted that the appellant has opted for settlement of the dispute under the Vivad Se Vishwas Scheme, 2016. It was submitted that pursuant to the declaration was filed under the Scheme, all statutory formalities have been duly completed.
The assessee has deposited the requisite taxes in accordance with the scheme. Last tax damand was deposited on 31/12/2019.
The learned AR further submitted that the Revenue has accepted the declaration and that Form-4, signifying final settlement of the dispute, has been issued on 10/11/2025. In view thereof, it was submitted that nothing survives for adjudication in the present appeal and the same may be disposed of accordingly.
Per contra, the learned Departmental Representative (DR) confirmed that the dispute involved in the present appeal has been resolved under the Vivad Se Vishwas Scheme. The learned DR placed on record Form-4 issued by the Revenue 2 and submitted that the declaration filed by the appellant has been accepted by the assessee and the settlement has attained finality. It was accordingly submitted that the appeal has become infructuous and is liable to be dismissed as not maintainable.
We have carefully considered the submissions of both the parties. We find that Form-4 dt. 10/11/2025 has been duly issued by the Revenue, evidencing that the dispute has been finally settled under the Vivad Se Vishwas Scheme and that the consideration has been fully resolved by the assessee. The said Form-4 forms part of the record.
In view of the above facts and the final settlement arrived at between the parties under the Vivad Se Vishwas Scheme, 2016 the present appeal does not survive for adjudication and is rendered non-maintainable.
In the result, appeal of the Assessee is dismissed.