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“Vivad se Vishwas”

Settlement & AmnestyDTVSV 2020DTVSV 20204,976 judgments

The decision most relied on for Vivad se Vishwas is Damodar Valley Corpn v. Addl. CIT (66 Taxmann.com 25), cited in 14 judgments on BharatTax.

Leading authorities on Vivad se Vishwas

Damodar Valley Corpn v. Addl. CIT
66 Taxmann.com 25 · 2016 · ITAT
14
citing judgments

The Tribunal's decision in the assessee's own case on a specific issue is binding on the Revenue for subsequent assessment years, especially when the assessee has availed the Vivad se Vishwas scheme and appeals have been dismissed on similar grounds.

Judgments citing Vivad se Vishwas

Yograjsinh G. Jadeja, Rajkot vs. The ITO Ward 1 (1) (1) Rajkot, Rajkot

In the result, the appeal of the assessee is allowed for statistical purposes in above terms

ITA 754/RJT/2025[2017-18]Status: DisposedITAT Rajkot12 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 754/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Yograjsinh G. Jadeja, The Ito, At Chapabeda, Ward – 1(1)(1), Vs. Ta, Kotda Sangani, Rajkot Rajkot-360030 Gujarat "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfqpj9355F (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: NoneFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 144Section 4(2)Section 5Section 5(1)

parte order, u/s. 144 of the Act and ld. CIT(A) has dismissed the appeal of the assessee, as the assessee adopted the vivad se vishwas,(VSV) scheme. Therefore, now this appeal becomes infructuous. However, ld. D.R. submitted that appeal of the assessee should be restored back to the file ... document and evidences were submitted before the A.O. during the assessment proceedings. On appeal, ld. CIT(A) noted that assessee adopted Vivad- Se- Vishwas scheme,(VSV) Scheme, therefore, ld. CIT(A) has dismissed the appeal of the assessee, observing as under: “3.1 have carefully considered the facts of the case

Rasar Biogenetics, Hyderabad vs. ITO., Ward-10(1), Hyderabad

ITA 1266/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-2017

Bench: Us:

Section 10Section 143(3)Section 28

amount. 7. Aggrieved, the assessee firm carried the matter in appeal before the CIT(A). 8. In the meantime, the assessee opted for Vivad-Se-Vishwas- Scheme (VSVS) as per the Vivad Se Vishwas Act, 2020, and duly filed the declaration in Form-2, Page No.21

Assistant Commissioner of Income Tax-19(3), Mumbai vs. Rajen Kirtilal Shah, Mumbai

Accordingly, all the grounds raised by the Revenue are dismissed

ITA 5438/MUM/2025[2013-14]Status: DisposedITAT Mumbai07 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharmil JhaveriFor Respondent: Shri Annavaran Kosuri
Section 144Section 144BSection 147Section 68

preferred appeal against the aforesaid assessment order [vide acknowledgment no 378207561290118, dated 29/01/2018]. The aforesaid tax dispute was settled under the Direct Tax Vivad se Vishwas Act, 2020. The Assessee received Form 5 being order for full and final settlement of tax arrears under Section 5(2) read with Section ... Direct Tax Vivad Se Vishwas Act, 2020 [Acknowledgement No.634768301270522, dated 27/05/2022.] 6. On 30/06/2021 the Assessing Officer issued the notice under Section 148 of the Act initiating reassessment proceedings for the same Assessment Year 2013-2014. According to the Assessing Officer as per the information received from the office

Solenis Chemicals India Private Limited, Ankleshwar vs. Assessment Unit (Jao Assistant Commissioner of Income Tax - 1(3)(1), Mumbai)

Accordingly, the appeal filed by the assessee is dismissed as withdrawn

ITA 4718/MUM/2024[2020-21]Status: DisposedITAT Mumbai07 Jan 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 91Section 91(3)

filed an application dated 26/12/2025 seeking withdrawal of the appeal, stating that it has opted to settle the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024. 3. The Ld.AR submitted that, the assessee has: • filed Form No. 1 under section 91 of the DTVSV Scheme, 2024; 2 I.T.A ... records placed before us. 5. Since the issues contested in the appeal of the assessee have been settled under the Direct Taxes Vivad Se Vishwas Act, 2024, we dismiss the appeal of the assessee as withdrawn. However, we give liberty to the assessee to seek recall of this order

DCIT, Central Circle-5(4), Mumbai vs. Sunil Bhagwatlal Dalal, Mumbai

In the result, both the Revenue’s appeals are partly allowed and

ITA 4047/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Jan 2026AY 2016-17

Bench: Shri Justice (Retd.) C. V. Bhadang&

Section 143(3)Section 69Section 69A

case of Monish Ghansham Makhija for AY 2016-17 was accepted by Shri Monish Ghansham Makhija and taxes were paid by him in Vivad se Vishwas Scheme. Page |4 ITA No. 4046, 4047/Mum/2025 CO No. 213, 214/Mum/2025 A.Y. 2015-16, 2016-17 Sunil Bhagwatlal Dalal, Mumbai The grounds of cross ... whose case, similar addition was made on the basis of the affidavit of Sri Chabaria and settled the dispute by availing Direct Vivad se Vishwas Scheme. Thus, affidavit filed by Sanjay Chhabria was corroborative material or evidence which explains entries in seized Tally file named ‘Balu’. Seized material were supported

DCIT, Central Circle 5(4), Mumbai vs. Sunil Bhagwatlal Dalal, Mumbai

In the result, both the Revenue’s appeals are partly allowed and

ITA 4046/MUM/2025[2015-16]Status: DisposedITAT Mumbai02 Jan 2026AY 2015-16

Bench: Shri Justice (Retd.) C. V. Bhadang&

Section 143(3)Section 69Section 69A

case of Monish Ghansham Makhija for AY 2016-17 was accepted by Shri Monish Ghansham Makhija and taxes were paid by him in Vivad se Vishwas Scheme. Page |4 ITA No. 4046, 4047/Mum/2025 CO No. 213, 214/Mum/2025 A.Y. 2015-16, 2016-17 Sunil Bhagwatlal Dalal, Mumbai The grounds of cross ... whose case, similar addition was made on the basis of the affidavit of Sri Chabaria and settled the dispute by availing Direct Vivad se Vishwas Scheme. Thus, affidavit filed by Sanjay Chhabria was corroborative material or evidence which explains entries in seized Tally file named ‘Balu’. Seized material were supported

DCIT, New Delhi vs. M/S. Cargil India Pvt. Ltd., New Delhi

In the result the appeal of the Revenue is dismissed

ITA 5786/DEL/2014[2005-06]Status: DisposedITAT Delhi30 Dec 2025AY 2005-06

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2005-06 Acit, Circle5(2), Vs. M/S Cargil India Pvt.Ltd. New Delhi -110001 111 Rectangle–I Saket District Centre New Delhi Pan No. Aaacc3269J (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 36(1)(iii)

prior years were routed through Capital Work in Progress. It is also submitted that assessee has been settled the issue in Direct Tax Vivad se Vishwas Scheme, 2020. The increase in fixed assets of the assessee was only because of the fact that Capital Work in Progress of Rs.1 ... transaction approach and further the adjustment sustained by the CIT(A) is Rs. 3,82,367/- was accepted by the taxpayer through Vivad Se Vishwas Scheme 2020. In view of above, we do not find any infirmity in the findings of the Ld. CIT(A), hence, we uphold the same

Rajendra Shripati Jadhav, Satara vs. Income Tax Officer Ward -2, Satara

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2000/PUN/2025[2011-12]Status: DisposedITAT Pune19 Dec 2025AY 2011-12

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2000/Pun/2025 Assessment Year : 2011-12

For Appellant: Shri Prayag Jha and Shri Prateek JhaFor Respondent: Shri Manoj Tripathi
Section 143(1)(a)Section 143(2)Section 143(3)

mainly on account of the reason that the assessee was exploring the possibility of settling the tax dispute under ‘The Direct Tax Vivad Se Vishwas Scheme’ and after successfully filing Form No.1, the Department has issued Form No.2 but thereafter the 2 Rajendra Shripati Jadhav assessee could not proceed with ... ld.CIT(A) within 30 days of receiving the Assessment Order. However, in the meantime, the Tax Dispute Settlement Scheme, i.e. The Direct Tax Vivad Se Vishwas Scheme has been launched by the Government and the assessee in order to take benefit of such scheme made application in Form No.1

Rajesh Soni HUF, Kolkata vs. ITO, Ward 33(7), Kolkata

Appeals of the assessee are hereby dismissed as withdrawn

ITA 2333/KOL/2025[2013-2014]Status: DisposedITAT Kolkata19 Dec 2025AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

been filed by the assessee for withdrawal of appeals stating therein that the assessee, in all the four appeals/cases, has already gone into Vivad Se Vishwas Scheme 2024 (VSVS 2024 Scheme), and the assessee has received the acknowledgement of Form 4. Therefore, the assessee prayed that the appeals

Rajesh Soni HUF, Kolkata vs. ITO, Ward 33(7), Kolkata

Appeals of the assessee are hereby dismissed as withdrawn

ITA 2332/KOL/2025[2012-2013]Status: DisposedITAT Kolkata19 Dec 2025AY 2012-2013

Bench: SHRI RAJESH KUMAR (Accountant Member)

been filed by the assessee for withdrawal of appeals stating therein that the assessee, in all the four appeals/cases, has already gone into Vivad Se Vishwas Scheme 2024 (VSVS 2024 Scheme), and the assessee has received the acknowledgement of Form 4. Therefore, the assessee prayed that the appeals

Sri Rajesh Soni, Kolkata vs. I.T.O., Ward-33(7), Kolkata

Appeals of the assessee are hereby dismissed as withdrawn

ITA 2331/KOL/2025[2013-14]Status: DisposedITAT Kolkata19 Dec 2025AY 2013-14

Bench: SHRI RAJESH KUMAR (Accountant Member)

been filed by the assessee for withdrawal of appeals stating therein that the assessee, in all the four appeals/cases, has already gone into Vivad Se Vishwas Scheme 2024 (VSVS 2024 Scheme), and the assessee has received the acknowledgement of Form 4. Therefore, the assessee prayed that the appeals

Sri Rajesh Soni, Kolkata vs. I.T.O. Ward-33(7), Kolkata

Appeals of the assessee are hereby dismissed as withdrawn

ITA 2330/KOL/2025[2012-13]Status: DisposedITAT Kolkata19 Dec 2025AY 2012-13

Bench: SHRI RAJESH KUMAR (Accountant Member)

been filed by the assessee for withdrawal of appeals stating therein that the assessee, in all the four appeals/cases, has already gone into Vivad Se Vishwas Scheme 2024 (VSVS 2024 Scheme), and the assessee has received the acknowledgement of Form 4. Therefore, the assessee prayed that the appeals

Om Prakash Agarwal, Mathura vs. ITO., Ward-3(3), Mathura

In the result, appeal of the assessee is dismissed in the terms aforesaid

ITA 290/AGR/2017[2007-08]Status: DisposedITAT Agra18 Dec 2025AY 2007-08

Bench: Shris.Rifaur Rahmanom Prakash Agarwal, Vs. Ito, Ward 3 (3), Prop. M/S. Khushboo Jewllers, Mathura. Shop No.133, Brijwasi Complex, Gurhai Bazar, Mathura – 281 001 (Uttar Pradesh). (Pan : Aawpa1280E) (Appellant) (Respondent) Assessee By : Shri Rajesh Malhotra, Ca Revenue By : Shri Shailender Shrivastava, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Order : 18.12.2025 O R D E R 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-1, Agra Dated 24.03.2017 For Ay 2007-08. 2. The Ld. Ar For The Assessee Has Submitted That Since The Assessee Has Settled The Issue Under Vivad Se Vishwas Scheme, 2024 (In Short ‘Vsvs’), Hence, The Assessee Wishes To Withdraw The Instant Appeal. In This Behalf, The Ld. Ar For The Assessee Submitted That Requisite Forms Have Been Received From The Department Accepting The Declaration Filed By The Assessee & Filed Form 5 On Record. Ld. Dr Did Not Controvert The Aforesaid Proposition. In View Of The Aforesaid, Appeal Of The Assessee Is Dismissed As Withdrawn.

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Shailender Shrivastava, Sr. DR

assessee has submitted that since the assessee has settled the issue under Vivad Se Vishwas Scheme, 2024 (in short ‘VSVS’), hence, the Assessee wishes to withdraw the instant appeal. In this behalf, the Ld. AR for the assessee submitted that requisite Forms have been received from the Department accepting

Shri Nitin Agarwal, Gwalior vs. ITO 3(2), Gwalior

In the result, appeal of the assessee is dismissed in the terms aforesaid

ITA 2/AGR/2017[2009-10]Status: DisposedITAT Agra18 Dec 2025AY 2009-10

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Pankaj Gargh, AdvocateFor Respondent: Shri Shailender Shrivastava, Sr. DR

Assessment Year 2009-10. 2. The Ld. AR for the assessee has submitted that since the assessee has settled the issue under Vivad Se Vishwas Scheme, 2024 (in short ‘VSVS’), hence, the Assessee wishes to withdraw the instant appeal. In this behalf, the Ld. AR for the assessee submitted that

Damodar Mangalji & Company Limited, Panaji vs. Assistant Commissioner of Income Tax, Circle - 1(1), Panaji

Appeals stands DISMISSED

ITA 35/PAN/2025[2014-15]Status: DisposedITAT Panaji18 Dec 2025AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

For Appellant: Adv Rahul Sarda [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 143(1)Section 143(3)Section 14ASection 250Section 253(1)Section 253(3)Section 37(1)Section 40(1)(i)

concerned, vide letter dt. 20/02/2020 the appellant through its appointed AR’s communicated of its consideration to settle AY 2011-12 dispute under ‘Vivad Se Vishwas ITAT-Panaji Page 16 of 32 Damodar Mangalji & Company Ltd. Vs JCIT/ACIT ITA Nos.034 & 035/PAN/2025 AY: 2011-12 & 2014-15 Act/Scheme’ [‘VSVA’] and thus

Damodar Mangalji & Company Limited, Panaji vs. The Joint Commissioner of Income Tax, Range - 1, Panaji

Appeals stands DISMISSED

ITA 34/PAN/2025[2011-12]Status: DisposedITAT Panaji18 Dec 2025AY 2011-12

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

For Appellant: Adv Rahul Sarda [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 143(1)Section 143(3)Section 14ASection 250Section 253(1)Section 253(3)Section 37(1)Section 40(1)(i)

concerned, vide letter dt. 20/02/2020 the appellant through its appointed AR’s communicated of its consideration to settle AY 2011-12 dispute under ‘Vivad Se Vishwas ITAT-Panaji Page 16 of 32 Damodar Mangalji & Company Ltd. Vs JCIT/ACIT ITA Nos.034 & 035/PAN/2025 AY: 2011-12 & 2014-15 Act/Scheme’ [‘VSVA’] and thus

Shashikala Vinaykumar, Mangaluru vs. Asst. Commissioner of Income Tax, Circle - 1 (1) and Tps Mangalore, Mangaluru

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 8/BANG/2025[2014-15]Status: DisposedITAT Bangalore15 Dec 2025AY 2014-15

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Smt. Vanaja, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR
Section 10(14)Section 143Section 147Section 148Section 201Section 271(1)Section 57

also filed her written submissions in which the assessee had informed about the intention of the company to settle the dispute under the Vivad se Vishwas (VsV) Scheme and also informed that the disputed tax as per Vivad se Vishwas form – 3 also paid within the period prescribed and submitted ... form -4 and 5 has to be issued by the authority. The Ld.CIT(A) by relying on section 4 of The Direct Tax Vivad Se Vishwas Act, 2020, had disposed the appeal as withdrawn. 4. As against the said order, the present appeal is filed by the assessee

Shashikala Vinaykumar, Mangaluru vs. Asst. Commissioner of Income Tax, Circle - 1 (1) and Tps Mangalore, Mangaluru

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 7/BANG/2025[2012-13]Status: DisposedITAT Bangalore15 Dec 2025AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Appellant: Smt. Vanaja, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR
Section 10(14)Section 143Section 147Section 148Section 201Section 271(1)Section 57

also filed her written submissions in which the assessee had informed about the intention of the company to settle the dispute under the Vivad se Vishwas (VsV) Scheme and also informed that the disputed tax as per Vivad se Vishwas form – 3 also paid within the period prescribed and submitted ... form -4 and 5 has to be issued by the authority. The Ld.CIT(A) by relying on section 4 of The Direct Tax Vivad Se Vishwas Act, 2020, had disposed the appeal as withdrawn. 4. As against the said order, the present appeal is filed by the assessee

Vinaya Kumar, Mangalore vs. ACIT, Circle-1(1) & Tps, Mangaluru

ITA 2180/BANG/2024[2012-13]Status: DisposedITAT Bangalore12 Dec 2025AY 2012-13

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Smt. Vanaja, Advocate
Section 143(3)Section 144

dismissed the appeal of the Assessee infructuous as according to the database it was shown that Assessee has obtained settlement of dispute under Vivad se Vishwas Scheme. The Assessee filed appeals before the ITAT which were originally dismissed by the another bench on the ground of the jurisdiction, later transferred ... without verifying the facts that the dispute in the Appeal has not been settled on account of non-payment of tax determined under Vivad se Vishwas Scheme. ITA Nos. 2178-2180/Bang/2024 Page 3 of 5 5. The Ld. Authorized Representative submitted that, that identical issue arose before the coordinate

Vinaya Kumar, Mangalore vs. ACIT, Circle-1(1) & Tps, Mangaluru

ITA 2179/BANG/2024[2015-16]Status: DisposedITAT Bangalore12 Dec 2025AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Smt. Vanaja, Advocate
Section 143(3)Section 144

dismissed the appeal of the Assessee infructuous as according to the database it was shown that Assessee has obtained settlement of dispute under Vivad se Vishwas Scheme. The Assessee filed appeals before the ITAT which were originally dismissed by the another bench on the ground of the jurisdiction, later transferred ... without verifying the facts that the dispute in the Appeal has not been settled on account of non-payment of tax determined under Vivad se Vishwas Scheme. ITA Nos. 2178-2180/Bang/2024 Page 3 of 5 5. The Ld. Authorized Representative submitted that, that identical issue arose before the coordinate