What did the High Court hold?

The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn, with liberty granted to the appellant to file appropriate applications if the assessee violated the scheme's conditions.

The assessee opted for the Direct Tax Vivad Se Vishwas Scheme, 2024, and Form No. 4 was issued. The appellant sought to withdraw the appeal due to the assessee's participation in the scheme.

What were the issues?

The primary issue was the impact of the assessee opting for the Vivad Se Vishwas Scheme on the pending appeal.

PCIT vs Sourabh Aggarwal Legal Heir of… | Punjab & Haryana High Court 2025

110-k IN THE HIGH COURT OF PUNJAB AND HARYANA

AT CHANDIGARH

CM-18355-57-CII-2025 in/and

ITA-95-2023 Date of Decision: September 15, 2025

THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), GURGAON

….. Appellant

Versus

SOURABH AGGARWAL LEGAL HEIR OF KAMLA AGGARWAL (DECEASED)

..... Respondent

CORAM:- HON'BLE MRS. JUSTICE LISA GILL

HON'BLE MRS. JUSTICE MEENAKSHI I. MEHTA

Present: Mr. Yogesh Putney, Senior Standing Counsel with Mr. Vaibhav Gupta, Advocate for the appellant.

Ms. Sonia Bohat, Advocate for Mr. Sukesh Kumar Jindal, Advocate for the respondent.

**** LISA GILL, J. CM-18355-CII-2025

This application seeking preponement of hearing of appeal is rendered infructuous. 2.

Application is disposed of accordingly. CM-18356-57-CII-2025 in/and ITA-95-2023 1.

Learned counsel for appellant submits that respondent – Assessee has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 and in pursuance thereof Form No. 4 has since been issued. RITU SHARMA 2025.09.18 12:21 I attest to the accuracy and integrity of this document

CM-18355-57-CII-2025 in/and ITA-95-2023

-2-

In view thereof, appellant seeks to withdraw this appeal with questions of law being kept open for adjudication in appropriate proceedings. He also seeks liberty to file appropriate application in case, it is found that respondent – Assessee has furnished incorrect declaration or has violated any conditions of the Scheme. 3.

Learned counsel for respondent verifies that Assessee has opted for the Scheme in question. 4.

Application is allowed and appeal is, accordingly, dismissed as withdrawn with liberty as aforementioned. 5.

Pending application(s), if any, stand(s) disposed of.

(LISA GILL)

JUDGE

(MEENAKSHI I. MEHTA) September 15, 2025

JUDGE Rts

Whether speaking/reasoned: Yes/No

Whether reportable: Yes/No

RITU SHARMA 2025.09.18 12:21 I attest to the accuracy and integrity of this document

THE PR. COMMISSIONER OF INCOME TAX (CENTRAL) GURUGRAM vs. SOURABH AGGARWAL LEGAL HEIR OF KAMLA AGGARWAL (DECEASED)

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Which sections of the Income-tax Act were involved?

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