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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

Gurmail Singh, Chandigarh vs. Income Tax Officer, Chandigarh

In the result, appeal of the assessee is dismissed as withdrawn

ITA 525/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh25 Feb 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 525/Chd/2024 "नधा"रण वष" / Assessment Year : 2011-12 Gurmail Singh, The Ito, बनाम H.No. 2667, Chandigarh Sector 37-C, Vs. Chandigarh "थायी लेखा सं./Pan No: Ajdps9389N 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 20.03.2024 Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2011-12. 2. During The Proceedings, An Application Dated 11.02.2025 (Wrongly Written As 11.02.2024) Has Been Filed By The Counsel Of The Assessee For Withdrawal Of This Appeal On The Ground That The Assessee Has Filed An Application In Form 1 Under The 525-Chd-2024 Gurmail Singh, Chandigarh

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

appeal on the ground that the Assessee has filed an application in Form 1 under the 525-Chd-2024 Gurmail Singh, Chandigarh 2 '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 Considering the prayer of the assessee, this appeal is dismissed as ‘withdrawn’ because in view of this settlement of dispute under 'Vivad Se Vishwas Scheme', it becomes infructuous.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

Anju Kaushal, Panchkula vs. Income Tax Officer, Ward-1, Panchkula

In the result, both the appeals are dismissed as withdrawn

ITA 759/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh25 Feb 2025AY 2010-11

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 758 & 759/Chd/2023 "नधा"रण वष" / Assessment Year: 2010-11 Anju Kaushal, The Ito, बनाम C/O Shri Tej Mohan Singh, Ward 1, Advocate, Panchkula Vs. # 527, Sector 10D, Chandigarh "थायी लेखा सं./Pan No: Afspk0769D 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 Vaadhan, 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 : Both The Appeals Have Been Filed By The Assessee Against The Separate Orders Dated 20.10.2023 & 24.11.2023 Respectively Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2010-11. 2. During The Proceedings, An Application Dated 23.01.2025 Has Been Filed By The Counsel Of The Assessee For Withdrawal Of Aforesaid Appeals On The Ground That The Assessee Has Opted

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

withdrawal of aforesaid appeals on the ground that the Assessee has opted 758 & 759-Chd-2023 Anju Kaushal, Panchkula 2 for Direct Tax 'Vivad Se Vishwas Scheme 2024’ and sought permission of the Bench to withdraw the aforementioned appeals. Necessary certificates in Form No.2 under Rule 5 have been issued ... Considering the prayer of the assessee, both the appeals are 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

Anju Kaushal, Panchkula vs. Income Tax Officer, Ward-1, Panchkula

In the result, both the appeals are dismissed as withdrawn

ITA 758/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh25 Feb 2025AY 2010-11

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 758 & 759/Chd/2023 "नधा"रण वष" / Assessment Year: 2010-11 Anju Kaushal, The Ito, बनाम C/O Shri Tej Mohan Singh, Ward 1, Advocate, Panchkula Vs. # 527, Sector 10D, Chandigarh "थायी लेखा सं./Pan No: Afspk0769D 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 Vaadhan, 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 : Both The Appeals Have Been Filed By The Assessee Against The Separate Orders Dated 20.10.2023 & 24.11.2023 Respectively Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’], For The Assessment Year 2010-11. 2. During The Proceedings, An Application Dated 23.01.2025 Has Been Filed By The Counsel Of The Assessee For Withdrawal Of Aforesaid Appeals On The Ground That The Assessee Has Opted

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

withdrawal of aforesaid appeals on the ground that the Assessee has opted 758 & 759-Chd-2023 Anju Kaushal, Panchkula 2 for Direct Tax 'Vivad Se Vishwas Scheme 2024’ and sought permission of the Bench to withdraw the aforementioned appeals. Necessary certificates in Form No.2 under Rule 5 have been issued ... Considering the prayer of the assessee, both the appeals are 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

M/S Metlonics Industries Pvt. Ltd., Chandigarh vs. DCIT, C-1(1), Chandigarh

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

ITA 1239/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh25 Feb 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1239/Chd/2019 "नधा"रण वष" / Assessment Year : 2011-12 M/S Metlonics Industries The Dcit, बनाम Pvt. Ltd., Circle 1(1), Plot No. 118, Industrial Chandigarh Vs. Area Phase -2, Chandigarh "थायी लेखा सं./Pan No: Aaccm2009A 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 18.07.2019 Of Ld. Commissioner Of Income Tax (Appeals)-1, Chandigarh [Herein Referred To As ‘Cit(A)’], For The Assessment Year 2011-12. 2. During The Proceedings, None Appeared On Behalf Of The Assessee. However, An Application Has Been Filed By The Assessee On 24.02.2025 For Withdrawal Of This Appeal On The Ground That The Assessee Has Opted For The 'Vivad Se Vishwas

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

been filed by the Assessee on 24.02.2025 for withdrawal of this appeal on the ground that the Assessee has opted for the 'Vivad Se Vishwas 1239-Chd-2019 M/s Metlonics Industries Pvt Ltd, Chandigarh 2 Scheme 2024’ and sought permission of the Bench to withdraw the aforementioned appeal. Necessary certificate ... 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

D.Y. Patil Education Society, Kolhapur vs. Assistant Commissioner of Income-Tax, Central Circle, Kolhapur

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 538/PUN/2020[2012-13]Status: DisposedITAT Pune25 Feb 2025AY 2012-13

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Nt Commissioner of Income-Tax, Central Circle, Kolhapur

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 537/PUN/2020[2011-12]Status: DisposedITAT Pune25 Feb 2025AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Assistant Commissioner of Income-Tax, Central Circle, Kolhapur

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 536/PUN/2020[2010-11]Status: DisposedITAT Pune25 Feb 2025AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Assistant Commissioner of Income-Tax, Central Circle, Kolhapur

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 535/PUN/2020[2009-10]Status: DisposedITAT Pune25 Feb 2025AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Deputy Commissioner of Income Tax

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 2744/PUN/2016[2012-13]Status: DisposedITAT Pune25 Feb 2025AY 2012-13

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Deputy Commissioner of Income Tax

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 2743/PUN/2016[2011-12]Status: DisposedITAT Pune25 Feb 2025AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Deputy Commissioner of Income Tax

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 2742/PUN/2016[2010-11]Status: DisposedITAT Pune25 Feb 2025AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

D.Y. Patil Education Society, Kolhapur vs. Deputy Commissioner of Income Tax

In the result, all the 8 appeals filed by the assessee are dismissed as “withdrawn”

ITA 2741/PUN/2016[2009-10]Status: DisposedITAT Pune25 Feb 2025AY 2009-10

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: None (VSVS application filed)For Respondent: Shri Ramnath P Murkunde

assessee filed the applications seeking withdrawal of all the 8 appeals on the ground that it has opted for Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSVS Scheme, 2024) and has also enclosed Form No.1 filed under the (DTVSVS Scheme, 2024) and Form No.2 issued by the PCIT, Centra

Dasan India Private Limited, Vijayawada vs. DCIT., Circle -1(1), Tirupati

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

ITA 954/HYD/2024[2020-21]Status: DisposedITAT Hyderabad25 Feb 2025AY 2020-21

Bench: Shri K Narasimha Chary & Shri Madhusudan Sawdia

For Respondent: : |Ms. M Narmada, CIT-DR
Section 143(3)

letter stating that, the assessee wants to withdraw the appeal as they have opted to resolve their dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSV,2024”). As stated by the assessee, they have already filed Form-1 under the DTVSV,2024 on 27.12.2024 and Form 2 under

Amar Chand Bohara, Chennai vs. The Assessing Officer Non Corp Ward 11(1), Chennai

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

ITA 3208/CHNY/2024[2017-18]Status: DisposedITAT Chennai25 Feb 2025AY 2017-18

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

For Appellant: NoneFor Respondent: Ms. Anitha, Addl. CIT

appeal is intended to be ITA No.3208 /Chny/2024 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 26.12.2024 vide acknowledgment No.774644910261224. 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

Enkay Life Realtors Pvt Ltd, Mumbai vs. ITO Ward 15(1)(1), Mumbai

The appeal is dismissed as scheme

ITA 20/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2013-14 Enkay Life Realtors Pvt. Ltd., Assessment Unit, Income –Tax Shop No. 21 Plot No. 55, Citi Department, Ito Ward 15(1)(1), Vs. Tower, Sector 15, Opp Aayakar Bhawan Room No. 456, Nimantran Restaurant, Cbd, 4Th Floor, Konkan Bhavan, S.O. Kokan Mumbai-400020. Bhavan, Thane-400614. Pan No. Aaica 6716 G Appellant Respondent

For Appellant: Ms. Ankita Gorde, CA (VirtuallyFor Respondent: 24/02/2025
Section 1Section 147Section 148Section 148A

settle the dispute by filing an that the assessee has opted to settle the dispute by filing an application under the Direct Tax Vivad Se Vishwas Scheme, Direct Tax Vivad Se Vishwas Scheme, application under the 2024. Accordingly, the assessee seeks to withdraw the present . Accordingly, the assessee seeks ... event that the Department does not accept the assessee’s a does not accept the assessee’s application under the pplication under the Vivad Se Vishwas Scheme, 2024 Vishwas Scheme, 2024. 3. The appeal of the assessee is accordingly dismissed. The appeal of the assessee is accordingly dismissed. The appeal

Ashwin Shamrao Bhalekar, Mumbai vs. ACIT, Circle-16(2), Mumbai

The appeal of the appellant is dismissed as withdrawn

ITA 2927/MUM/2023[2014-15]Status: DisposedITAT Mumbai25 Feb 2025AY 2014-15

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Ashwin Shamrao Bhalekar Acit-16(2) 201 Triveni Apartment Aayakar Bhavan Suchidham Complex Vs. M.K. Road Film City Road, Goregaon Mumbai-400 Mumbai-400063. 020. Pan : Aebpb5505Q Appellant Respondent

For Appellant: Shri Ram Krishn KediaFor Respondent: Shri Shashank Mehta
Section 10(38)

appellant filed a letter dated 7.1.2025 stating that the appellant filed Form No.1 and availing Direct Taxes 2 Vivad Se Vishwas Scheme (VSVS) and on 29.1.2025, the Ld. AR of the appellant has stated that the appellant availed the VSVS and may be allowed to withdraw the appeal

Rabo Shared Services Private Limited, Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO/NFAC Delhi, Delhi

In the result, the appeal of the assessee is dismissed

ITA 489/MUM/2022[2017-18]Status: DisposedITAT Mumbai25 Feb 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 Rabo Shared Services Pvt. Ltd., Add./Joint/Dy./Asst. Cit \/Ito, 20F, Tower A Peninsula National E-Assessment Centre, Vs. Business Park, Senapati Bapat Delhi. Marg, Lower Parel, Mumbai-400013. Pan No. Aaccr 5316 H Appellant Respondent

For Appellant: NoneFor Respondent: 24/02/2025
Section 92C

assessee has opted for the submitted that the assessee has opted for the submitted that the assessee has opted for the “Direct Tax Vivad Se Vishwas Scheme, 2024” “Direct Tax Vivad Se Vishwas Scheme, 2024” and has already and has already filed the prescribed Form No. 1 before the appropriate

Abdulrahiman Kunju Puthenveetil Mohammedkunju, Kayamkulam vs. ITO, Ward 1 & Tps, Alappuzha

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

ITA 541/COCH/2024[2016-2017]Status: DisposedITAT Cochin24 Feb 2025AY 2016-2017

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr.AR

appeal pending before this Tribunal on the ground Page 3 of 3 that the assessee had opted for the Direct Tax Vivad Se Vishwas Scheme, 2024 and also furnished the form -2 received from the department and further informed that the amount of Rs. 37,500/- as directed

Vimla Devi Jain (Deceased) Through Devendra Jain (Son), Ajmer vs. ITO, Ward 1(2), Ajmer

In the result, the appeal of the assessee is dismissed having been withdrawn

ITA 1505/JPR/2024[2011-12]Status: DisposedITAT Jaipur24 Feb 2025AY 2011-12

Bench: The Ld.Pcit, Udaipur Under Dtvsv Act, 1024 For Settling The Order Being Agitated In This Appeal & The Ld.Pcit Has Issued Form 2 Also & The Appellant Has Deposited Amount

For Appellant: Shri Mukesh Khandelwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT DR (VH)

materials available on record, it is found that the assessee is herself interested in withdrawing the appeal by settling the dispute, under Vivad Se Vishwas Scheme 2024. The Bench further feels that in case of another reasons the dispute is not settled in Vivad Se Vishwas Scheme 2024, the assessee

Santosh Kanwar, Jaipur vs. Ward- 7(3) Jaipur, Jaipur

In the result, the appeal of the assessee is dismissed having been withdrawn

ITA 1459/JPR/2024[2013-14]Status: DisposedITAT Jaipur24 Feb 2025AY 2013-14

Bench: The Bench.

For Appellant: Shri Shailesh Mantri, CAFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

assessee has prayed for withdrawal of the appeal on the ground of settlement of the dispute under Direct Tax Vivad Se Vishwas Scheme, 2024 2.2 On the other hand, the ld. DR did not raise any objection to the submissions made by the ld. AR of the assessee before ... materials available on record, it is found that the assessee is herself interested in withdrawing the appeal by settling the dispute, under Vivad Se Vishwas Scheme 2024. The Bench further feels that in case of another reasons the dispute is not settled in Vivad Se Vishwas Scheme 2024, the assessee