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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

Raj Kumar Bothra, Kolkata vs. ITO, Ward-37(3), Kolkata

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 2349/KOL/2024[2018-19]Status: DisposedITAT Kolkata26 Feb 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Kumar Bothra 2. At the time of hearing, it came to our notice that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) and he received Form 2 with the competent authority but there was certain error in issuing Form 2. Assessee orally prayed before

D.C.I.T./A.C.I.T., Circle - 7(1), Kolkata vs. Anther Vinimay Private Limited, Kolkata

In the result, the appeal filed by the revenue is disposed of in the light of above observation

ITA 2279/KOL/2024[2013-2014]Status: DisposedITAT Kolkata26 Feb 2025AY 2013-2014

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

time of hearing, it has been argued by the A/R that assessee has opted to for Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) by filing form no.1, with 2 I.T.A. No. 2279/Kol/2024 Assessment Year: 2013-14 Anther Vinimay Pvt. Ltd. the competent authority. His submission is that hearing

Shri Radha Krishna Ferro Alloys Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 2205/KOL/2024[2012-2013]Status: DisposedITAT Kolkata26 Feb 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Radha Krishna Ferro Alloys Pvt. Ltd. 2. At the time of hearing, it was pointed out that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) and therefore, prayed before the Bench that the assessee may be allowed to withdraw this appeal to which

Shanta Ajmera, Kolkata vs. I.T.O., Ward - 49(3), Kolkata

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 1901/KOL/2024[2013-2014]Status: DisposedITAT Kolkata26 Feb 2025AY 2013-2014

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Assessment Year: 2013-14 Shanta Ajmera 2. At the time of hearing, it was pointed out that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) by filing Form no. 2 with the competent authority and therefore, prayed before the Bench that the assessee

Manju Gupta, Kolkata vs. I.T.O., Ward - 47(1), Kolkata

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 1247/KOL/2024[2012-2013]Status: DisposedITAT Kolkata26 Feb 2025AY 2012-2013

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

dated 10.05.2024 for AY 2012-13. 2. At the time of hearing, it was pointed out that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) by filing Form no. 3 with the 2 I.T.A. No. 1247/Kol/2024 Assessment Year: 2012-13 Manju Gupta competent authority

Vidya Devi Miharia, Kolkata vs. ITO, Ward-36(1), Kolkata.

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 1236/KOL/2024[2014-15]Status: DisposedITAT Kolkata26 Feb 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1236/Kol/2024 Assessment Year: 2014-2015 Vidya Devi Miharia,………………………………,Appellant 2Nd Floor, Trpl Building, 15B, Armenian Street, Kolkata-700001 [Pan:Aenpm9853N] -Vs.- Income Tax Officer,……………….………….....Respondent Ward-36(1), Kolkata, Aayakar Bhawan Poorva, 110, Shanti Pally, Kolkata-700107 Appearances By: Shri Miraz D. Shah, A.R.,, Appeared On Behalf Of The Assessee Sm. Madhumita Das, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: February 24, 2025 Date Of Pronouncing The Order: February 26, 2025 O R D E R

time of hearing, it was pointed out by the ld. Counsel for the assessee that the assessee has already gone into Direct Tax Vivad Se Vishwas Scheme, 2024 (‘DTVSVS 2024’ Scheme) by filing 1 Vidya Devi Miharia Declarations with the Competent Authority and therefore, prayed before the Bench that

Megha Badurka, Kolkata vs. ITO, Ward-37(2), Kolkata

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 1397/KOL/2023[2012-13]Status: DisposedITAT Kolkata26 Feb 2025AY 2012-13

Bench: Shri Pradip Kumar Choubey& Shri Sanjay Awasthi]

Assessment Year: 2012-13 Megha Badurka 2. At the time of hearing, it was pointed out that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) and therefore, prayed before the Bench that the assessee may be allowed to withdraw this appeal to which

Junctions Hotel Private Limited, Siliguri vs. Income Tax Officer Ward 1(4) Siliguri, Siliguri

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 1282/KOL/2023[2017-18]Status: DisposedITAT Kolkata26 Feb 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey]

Jucntions Hotel Pvt. Ltd. 2. At the time of hearing, it was pointed out that the assessee has already gone into Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) and therefore, prayed before the Bench that the assessee may be allowed to withdraw this appeal to which

Thanakodi, Namakkal vs. ITO, Ward-3, Namakkal

In the result, the appeals filed by the assessee in ITA No

ITA 3283/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 Feb 2025AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.3283/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-2018) Thanakodi, Vs. The Income Tax Officer, 140, Nadar Street, Ward 3, Ariyagoundampatti, Namakkal. Namagiripettai, Rasipuram, Namakkal 637 406. [Pan: Anupt 9264C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. T.S.Lakshmi Venkatraman, Fca (Virtual) ""यथ" क" ओर से /Respondent By : Ms. V. Aswathy, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Mr. T.S.Lakshmi Venkatraman, FCAFor Respondent: Ms. V. Aswathy, JCIT

vide acknowledgment number 838199810240125 3. Accordingly, noting the fact that the assessee is opted for resolution of dispute under Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024, we treat this appeal being dismissed as withdrawn. 4. The assessee is given liberty for restoration of the present appeal in case ... resolution of dispute under Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024 is failed. 5. In the result, the appeals filed by the assessee in ITA No.3283/Chny/2024 is dismissed as withdrawn. Order pronounced in the open court on 25th day of February, 2025 at Chennai. (मनोज कुमार अ"वाल) (मनु

Chemin C and I Pvt. Ltd., Pondicherry vs. DCIT, Circle-1, Pondicherry

In the result, the appeal filed by the assessee in ITA Nos

ITA 2094/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 Feb 2025AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2094/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-2019) Chemin C & I Pvt Ltd, Vs. The Deputy Commissioner Of C-105, 106, 17Th Cross, Income Tax, Pipdic Industrial Estate, Circle 1, Mettupalayam, Pondicherry Pondicherry 605 009. [Pan: Aaccc 3561F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri P.M. Kathir, Advocate ""यथ" क" ओर से /Respondent By : Shri. Krishna Kumar, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri P.M. Kathir, AdvocateFor Respondent: Shri. Krishna Kumar, JCIT

that the present appeal is intended to be withdrawn by the appellant, for the purpose of opting the benefit under the Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024. Assessee also informed that Form No.1 DTVSV has been filed on 24.02.2025 vide acknowledgment No.881095300240225. 3. Accordingly, noting the fact that ... assessee is opted for resolution of dispute under Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024, we treat this appeal being dismissed as withdrawn. 4. The assessee is given liberty for restoration of the present appeal in case the resolution of dispute under Direct Tax Vivad Se Vishwas Scheme (DTVSV

Santha.G, Krishnagiri vs. Commissioner of Income Tax Appeals, Income Tax Department

In the result, the appeals filed by the assessee in ITA No

ITA 1714/CHNY/2024[2012-2013]Status: DisposedITAT Chennai26 Feb 2025AY 2012-2013

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.1714/Chny/2024 (िनधा"रणवष" / Assessment Year: 2012-2013) Santha G. Vs. The Income Tax Officer, 25/58, N. Thattahal, Ward 1, Valluvar Street, Krishnagiri. Pochampalli, Krishnagiri 635 204. [Pan: Degps 2164C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. D. Anand, Advocate ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.02.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

that the present appeals are intended to be withdrawn by the appellant, for the purpose of opting the benefit under the Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024. Assessee also informed that in all captioned appeals Form Nos.1 DTVSV has been filed on 18.12.2024 and Form No.2 are issued ... Assessment Year 2012-13. 3. Accordingly, noting the fact that the assessee is opted for resolution of dispute under Direct Tax Vivad Se Vishwas Scheme (DTVSV), 2024, we treat this appeal being dismissed as withdrawn. 4. The assessee is given liberty for restoration of the present appeal in case

Cargill the Netherlands Holding Bv, Netherlands vs. DCIT (International Taxation), Circle - 2(1), Bengaluru

In the result, appeal filed by the assessee is dismissed as withdrawn

ITA 1126/BANG/2024[AY 2011-12]Status: DisposedITAT Bangalore26 Feb 2025

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Shri Parth, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 250Section 91(2)Section 92Section 92(1)

dated 27.01.2025 filed on 06.02.2025 requesting for withdrawal of the appeal enclosing therein the copy of Form 1 filed under the Direct Tax Vivad Se Vishwas Scheme 2024 (DTVSV, 2024) as well as copy of Form-2 issued by the ld. Commissioner of Income Tax dated 27/01/2025 and submitted that ... dismiss this appeal of the assessee as withdrawn with liberty to reinstate the appeal if the assessee’s application under the Direct Tax Vivad Se Vishwas Scheme, 2024 is not accepted for any reason. IT(IT)A No.1126/Bang/2024 Cargill The Netherlands Holding BV, Netherlands Page

Priti Mishra, Allahabad vs. ACIT, Cir-1, Allahabad

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 90/ALLD/2024[2017-18]Status: DisposedITAT Allahabad25 Feb 2025AY 2017-18

Bench: Shri Subhash Malguria & Shri Nikhil Choudhary

Section 250Section 270(6)Section 270A

application was received from the assessee’s Authorized Representative pointing out that the assessee had opted for settlement of dispute under the Vivad Se Vishwas Scheme, 2024 and due taxes had been paid. Thereafter, Form No.3 had been issued by the Department. The assessee had to submit proof of withdrawal

Jai Wardhan, Delhi vs. ITO, Bihar

In the result, the appeal of the assessee is dismissed, as withdrawn

ITA 640/PAT/2024[2017-18]Status: DisposedITAT Patna25 Feb 2025AY 2017-18

Bench: The Bench That The Case May Be Adjourned Till The Vsvs Process Is Complete. It Is Seen That As Per The Vsvs The Assessee Has To Withdraw His Appeal As Per The Scheme.

dated 08.08.2024 for AY 2017- 18. 2.1 At the time of hearing, it was pointed out that the assessee has already opted for Vivad Se Vishwas Scheme 2024 ('VSVS 2024' Scheme) by filing Forms No.1 with the competent authority. The assessee has, therefore prayed before the Bench that the case

Lakhan Lal Malviya, Chicholi, Betul vs. NFAC, Delhi

ITA 484/IND/2024[2013-14]Status: DisposedITAT Indore25 Feb 2025AY 2013-14

आयकर अपीलीय अधिकरण, इंदौर (एकल सदस्यीय प्रकरण) न्यायपीठ, इंदौर श्री मनीष बोरड, लेखा सदस्य के समक्ष आ.अ.सं.484

M/S Kamal Auto Finance Pvt. Ltd., Jaipur vs. DCIT, Circle-1, Jaipur

Appeal is dismissed as having been withdrawn

ITA 1546/JPR/2024[2017-18]Status: DisposedITAT Jaipur25 Feb 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, CA. (Through VC)For Respondent: Sh. Gautam Singh Choudhary, JCIT-DR
Section 250

dismissed as having been withdrawn, as the appellant has moved appropriate application for settlement of the dispute availing of benefit of Direct Tax Vivad Se Vishwas Scheme, 2024. At the same time, it has been requested that the appellant be granted liberty to get the appeal revised, in case ... settlement under the Scheme i.e. Direct Tax Vivad Se Vishwas Scheme, 2024. 4. Alongwith application, copy of Form No. 2 has been submitted. Form No. 4 is stated to have not so far been issued. 5. Having regard to the prayer in the application and that the appellant intends

Sh. Banshi Dhar Yadav, Jaipur vs. ITO, Ward-7(1), Jaipur

Appeal is dismissed as having been withdrawn

ITA 1392/JPR/2024[2013-14]Status: DisposedITAT Jaipur25 Feb 2025AY 2013-14

Bench: The Ld. Addl. Cit(A) Has Been Dismissed Being Barred By Limitation.

For Appellant: Shri P.C. Parwal, CA.(through VC)For Respondent: Sh. Gautam Singh Choudhary, JCIT-DR
Section 143(3)

dismissed as having been withdrawn, as the appellant has moved appropriate application for settlement of the dispute availing of benefit of Direct Tax Vivad Se Vishwas Scheme, 2024. At the same time, it has been requested that the appellant be granted liberty to get the appeal revised, in case ... settlement under the Scheme i.e. Direct Tax Vivad Se Vishwas Scheme, 2024. 4. Alongwith application, copy of Form No. 2 has been submitted. Form No. 4 is stated to have not so far been issued. 5. Having regard to the prayer in the application and that the appellant intends

Leela Dutt Sharma, Chandigarh vs. Income Tax Officer, Ward 5(5), Chandigarh

In the result, appeal of the assessee is dismissed as withdrawn

ITA 929/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Feb 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 929/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 Leela Dutt Sharma, The Ito, बनाम Scf No. 566, Kesho Ram Ward 5 (5), Complex, Chandigarh Vs. Burail, Chandigarh "थायी लेखा सं./Pan No: Apaps8338G अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा""रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 25.02.2025 आदेश/Order Per Bench : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 16.08.2024 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2017-18. 2. During The Proceedings, None Appeared On Behalf Of The Assessee. However, An Application Dated 30.01.2025 Has Been Filed By The Assessee For Withdrawal Of This Appeal On The 929-Chd-2024 Leela Dutt Sharma, Chandigarh

For Appellant: None (Withdrawal Application)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 254(2)

withdrawal of this appeal on the 929-Chd-2024 Leela Dutt Sharma, Chandigarh 2 ground that the Assessee has opted for the 'Vivad Se Vishwas Scheme 2024’ and sought permission of the Bench to withdraw the aforementioned appeal. Necessary certificate in Form No.2 under Rule 5 has been issued ... record. 3. Considering the prayer of the assessee, this appeal is dismissed as ‘withdrawn’ because in view of this settlement of dispute under 'Vivad Se Vishwas Scheme', it becomes infructuous. However, it is made clear that in case, on account of some technicalities, assessee fails to avail the full benefit

Sandhya Rani, Yamuna Nagar vs. Income Tax Officer, Ward-4, Yamuna Nagar

In the result, appeal of the assessee is dismissed as withdrawn

ITA 830/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh25 Feb 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 830/Chd/2024 "नधा"रण वष" / Assessment Year : 2015-16 Sandhya Rani, The Ito, बनाम C/O Tej Mohan Singh, Ward 4, Advocate, Yamunanagar Vs. 527, Sector 10-D, Chandigarh "थायी लेखा सं./Pan No: Auopr2187B अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा""रती क" ओर से/Assessee By : Shri Tej Mohan Singh, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 25.02.2025 आदेश/Order Per Bench : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 18.06.2024 Of Ld. Addl. / Joint Commissioner Of Income Tax (Appeals)-1, Delhi For The Assessment Year 2015-16. 2. During The Proceedings, An Application Dated 31.01.2025 Has Been Filed By The Counsel Of The Assessee For Withdrawal Of This Appeal On The Ground That The Assessee Has Moved An Application Under The Direct Tax 'Vivad Se Vishwas Scheme

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr.DR
Section 254(2)

Counsel of the Assessee for withdrawal of this appeal on the ground that the Assessee has moved an application under the Direct Tax 'Vivad Se Vishwas Scheme 830-Chd-2024 Sandhya Rani, Yamunanagar 2 2024’ and sought permission of the Bench to withdraw the aforementioned appeal. Necessary certificate in Form ... record. 3. Considering the prayer of the assessee, this appeal is dismissed as ‘withdrawn’ because in view of this settlement of dispute under 'Vivad Se Vishwas Scheme', it becomes infructuous. However, it is made clear that in case, on account of some technicalities, assessee fails to avail the full benefit

Vijay Sharma, Ropar vs. Income Tax Officer Ward 2(4) Ropar, Ropar

In the result, appeal of the assessee is dismissed as withdrawn

ITA 724/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh25 Feb 2025AY 2013-14

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 724/Chd/2024 "नधा"रण वष" / Assessment Year : 2013-14 Vijay Sharma, The Ito, बनाम Kaplish Niwas, Ward 2(4), Gurudwara Road, Ropar Vs. Ropar "थायी लेखा सं./Pan No: Aceps9708H अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा""रती क" ओर से/Assessee By : None (Withdrawal Application) राज"व क" ओर से/ Revenue By : Shri Ved Parkash Kalia, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 25.02.2025 आदेश/Order Per Bench : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 26.04.2024 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2013-14. 2. During The Proceedings, None Appeared On Behalf Of The Assessee. However, An Application Dated 22.02.2025 Through E.Mail Has Been Filed By The Counsel Of The Assessee For Withdrawal Of This Appeal On The Ground That The Assessee Has Opted To Take Benefit Under The Direct Tax 'Vivad Se Vishwas

For Appellant: None (Withdrawal Application)For Respondent: Shri Ved Parkash Kalia, Sr.DR
Section 254(2)

Assessee for withdrawal of this appeal on the ground that the Assessee has opted to take benefit under the Direct Tax 'Vivad Se Vishwas 724-Chd-2024 Vijay Sharma, Ropar 2 Scheme 2024’ and sought permission of the Bench to withdraw the aforementioned appeal. Necessary certificate in Form No.2 under ... record. 3. Considering the prayer of the assessee, this appeal is dismissed as ‘withdrawn’ because in view of this settlement of dispute under 'Vivad Se Vishwas Scheme', it becomes infructuous. However, it is made clear that in case, on account of some technicalities, assessee fails to avail the full benefit