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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

Judgments citing Vivad se Vishwas

Enel Green Power India Private Limited, Mayur Vihar, East Delhi vs. DCIT Circle 7(1), Delhi, Cr Building, ITO

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

ITA 4298/DEL/2024[2020-2021]Status: DisposedITAT Delhi30 Oct 2025AY 2020-2021

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekenel Green Power India Private Limited, Vs. Dcit, Circle 7(1), S – 2, Manish Chambers, Delhi. Dda Local Shopping Complex, Mayur Vihar, Phase Ii, Delhi – 110 091. (Pan : Aaecb2266J) (Appellant) (Respondent) Assessee By : Shri Yishu Goel, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 30.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Yishu Goel, ARFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)

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 declaration in Form No.1 is filed and Form No.2 ... receive from the tax authorities, as per the Vivad Se Vishwas Rules, 2020. Ld. DR did not controvert the aforesaid proposition. In view of the aforesaid, appeal of the Assessee is dismissed as withdrawn. 3. Liberty is granted to the Assessee to revive appeal in the event application filed

Shri Ravichandra Mannar Nidu, Chennai vs. ITO Non Corporate Ward 2 (3), Chennai

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

ITA 3101/CHNY/2017[2014-15]Status: DisposedITAT Chennai28 Oct 2025AY 2014-15

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.3101/Chny/2017 ननिाारण वर्ा/Assessment Year: 2014-15 V. Shri Ravichandra Mannar Naidu, Income Tax Officer, Door No.5/3, Muthurangan Block, Non-Corporate Ward-2(3), Sivaguru Street, Chennai. Jaffarkhanpet, Chennai-600 083. [Pan: Ajopm6388E] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Ms.Sriharini, Advocate For Mr.R.Vijayaraghavan, Advocate. : प्रत्यर्थी की ओर से /Respondent By Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 21.08.2025 घोर्णाकीतारीख /Date Of Pronouncement : 28.10.2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-2, Chennai [Cit(A)] Dated 23.10.2017 For Assessment Year 2014-15. 2. At The Outset, The Ld. Counsel For The Assessee Submitted A Letter Dated 07.08.2025 Wherein Stated 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 In Captioned Appeal Form Nos.2 Dtvsv Is Issued For Shri Ravichandra Mannar Naidu

stated 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 in captioned appeal Form Nos.2 DTVSV is issued for Shri Ravichandra Mannar Naidu the Assessment Years ... vide acknowledgment Number 489862941290725 dated 29.07.2025. 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

Deepsikha Distributors Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(1), Kolkata

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

ITA 1714/KOL/2025[2012-2013]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Deepsikha Distributors Pvt. Ltd..……………………………….…….……Appellant 15/2/1, Deodar Street, Kolkata-700019. [Pan: Aaacd9515E] Vs. Ito, Ward-6(1), Kolkata..………………………..………...……...…..…..Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.06.25 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”). Brief Facts Of The Case Are That The Assessee Is Engaged In The 2. Business Of Investment In Shares & Filed Its Return Of Income On For A.Y. 2012-13 U/S 139(1) Of The Act Declaring Total Income Of Rs.279/-. The Return Was Selected For Scrutiny & An Order U/S 143(3) Of The Act Was Passed On 17.03.2015 Assessing Total Income Of The Assessee At Rs.1,15,00,279/- By Adding Rs.1,15,00,000/- As Unexplained Cash Credit U/S 68 Of The Act. After That, The Assessee Went In Appeal Before The Ld. Cit(A) & The Ld. Cit(A) Vide Order Dated 30.06.2015 Allowed The Appeal Deepsikha Distributors Pvt. Ltd Of The Assessee. Thereafter, The Revenue Preferred Appeal Before The Itat Wherein The Tribunal Set Aside The Order Of The Ld. Cit(A) & Asked The Assessing Officer To Pass De Novo Assessment & The Assessing Officer Vide Fresh Assessment Order U/S 254/250/143(3) Of The Act Sustained The Same Addition Of Rs.1,15,00,000/- U/S 68 Of The Act As Unexplained Cash Credit.

Section 139(1)Section 143(3)Section 250Section 254Section 68

appeal for AY 2012-13 This is to inform Your Honour that the appellant has decided to settle the dispute and opted for Vivad Se Vishwas Scheme, 2020 for the above mentioned appeal by filing declaration in Form 1 and 2. Accordingly, Your Honour is requested to kindly treat ... assessee has come in appeal before us. The ld. AR submits that Form No.3 was not allowed by the department to avail the Vivad Se Vishwas Scheme, 2020. The ld. AR has only prayed that the appeal of the assessee may be restored to the file

DCIT, Gurgaon vs. Omaxe Limited, New Delhi

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

ITA 2403/DEL/2025[2014]Status: DisposedITAT Delhi24 Oct 2025

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roydcit, Vs. Omaxe Limited, Gurugram. 7, Local Shopping Centre, Kalkaji, New Delhi – 110 016. (Pan : Aaaco0171H) (Appellant) (Respondent) Assessee By : Shri Akshat Jain, Ca Shri Rajat Jain, Ca Revenue By : Ms. Garima Mathur, Sr. Dr Date Of Hearing : 23.09.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals), Delhi-44 Dated 13.02.2025 For Ay 2014-15 Raising Following Grounds Of Appeal :- “(I) Whether Ld. Cit(A) Has Erred In Allowing Deduction U/S 80Ib (10) Of The Act To The Tune Of Rs.5,22,08,123/- In Respect Of The Profits From Housing Project Which Are Group Housing Scheme Of Multi-Storied Flats In The Projects Namely M/S Royal Residency, Ludhiana? (Ii) Whether Ld. Cit(A) Has Erred In Following The Order Of Ld. Cit(A) - 19 For The Ay 2011-12 Wherein It Was Held That The Aforesaid Group Housing Scheme Is Separately Satisfying The Conditions Laid Down In The Provisions Of 2 Section 80Ib(10) Despite Observing That The Consolidated Approval Of The Local Authority Is For The Entire Project? (Iii) Whether The Decision Of Ld. Cit(A) Does Not Suffer From The Vice Of Perversity? (Iv) Whether Ld. Cit(A) Has Erred In Law & On Facts By Determining The Credit Spread At 500 Basis Points, Relying Upon The Guidelines Issued By Reserve Bank Of India For External Commercial Borrowing? (V) Whether Ld. Cit(A) Has Erred In Law & On Facts By Ignoring The Judgment Of Hon'Ble High Court?”

For Appellant: Shri Akshat Jain, CAFor Respondent: Ms. Garima Mathur, Sr. DR
Section 80I

LIBOR + 100 or 200 is concerned, the issue was settled by the assessee before the Income Tax Authorities thereby filing application under “Vivad Se Vishwas Scheme”. Besides this, the CIT(A) has directed the AO/TPO to charge interest rate at the rate of LIBOR+5% on the loan advanced ... LIBOR + 100 or 200 is concerned, the issue was settled by the assessee before the Income Tax Authorities thereby filing application under “Vivad Se Vishwas Scheme”. Besides this, the CIT(A) has directed the AO/TPO to charge interest rate at the rate of LIBOR+5% on the loan advanced

Rajesh Kumar Pandey, Ramgarh vs. ITO, Ward 2(4), Rangarh

In the result, the appeal of the assessee is dismissed as withdrawn, with liberty as stated above

ITA 402/RAN/2024[2011-12]Status: DisposedITAT Ranchi15 Oct 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.402/Ran/2024 Assessment Year: 2011-12 Rajesh Kr. Pandey…………….……………............................……….……Appellant M/S Ramgarh Sponge Iron, Near Punjab National Bank Main Road, Ramgarh, Jharkhand – 829122. [Pan: Auhpp5179N] Vs. Ito, Ward-2(4), Ramgarh.…...…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 13, 2025 Date Of Pronouncing The Order : October 15, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Ranchi, For The Assessment Year 2011–12. 2. At The Time Of Hearing, The Learned Authorised Representative (Ar) Of The Assessee Filed A Written Application Dated 13.10.2023, Submitting That The Instant Appeal Has Been Settled Under The “Vivad Se Vishwas Scheme, 2024” (Vsvs), As Per Section 91 Of The Finance (No. 2) Act, 2024. 3. It Was Further Submitted That The Competent Authority Has Been Pleased To Issue Form No. 2 Dated 21.08.2025, Thereby Accepting The Declaration Filed By The Assessee Under The Said Scheme. The Assessee Is Now Awaiting Issuance Of Form No. 4 For Final Settlement Of The Dispute. Accordingly, The Assessee Prayed For Permission To Withdraw The Present Appeal, With A Liberty To Seek Revival In The Event The Matter Is Not Ultimately Settled Under The Said Scheme.

Section 91

learned Authorised Representative (AR) of the assessee filed a written application dated 13.10.2023, submitting that the instant appeal has been settled under the “Vivad se Vishwas Scheme, 2024” (VSVS), as per Section 91 of the Finance (No. 2) Act, 2024. 3. It was further submitted that the competent authority ... liberty for revival if the settlement does not materialize. 5. We have considered the submissions. Since the assessee’s declaration under the Vivad se Vishwas Scheme, 2024 has been duly accepted by the competent authority, and Form No. 2 has already been issued, the instant appeal has become infructuous. Accordingly

Manimozhian Vaideki, Sivagangai vs. ACIT, International Taxation Circle, Madurai

In the result, the appeal of the assessee is allowed

ITA 2025/CHNY/2025[2016-17]Status: DisposedITAT Chennai15 Oct 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2025/Chny/2025 यनिाारणवर्ा / Assessment Year:2016-17 Manimozhian Vaideki, The Assistant Commissioner No.77, Ward-1, Devappattu Vs. Of Income Tax, Kallal, International Taxation Circle, Sivagangai, Madurai. Tamil Nadu-630 305. [Pan:Azcpv7593C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.N.Arjun Raj, Advocate प्रत्यर्थीकीओरसे/Revenue By : Ms.R.Anitha, Addl.Cit

For Appellant: Mr.N.Arjun Raj, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT
Section 144C(5)Section 148Section 148ASection 149Section 149(1)(a)

Panel issued directions under section 144C(5) of the Act and before the finalization of the final assessment order, the Assessee opted for Vivad Se Vishwas Scheme. The said Vivad Se Vishwas Scheme application stood rejected by the Learned Principal Commissioner of Income Tax. Thereafter, the Assessee filed a rectification ... disposed of by the Learned PCIT. Since the time was running out, the Assessee sought to waive the right of availing the Vivad Se Vishwas Scheme and proceeded to file an appeal before this tribunal with a delay of 113 days. Hence, it could be seen that Assessee was pursuing

DCIT, Ltu, Circle- 1 & 2, New Delhi vs. Indian Yamaha Motor Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed at the behest of the assessee to settle the issue under VSVS

ITA 6039/DEL/2018[2013-14]Status: DisposedITAT Delhi09 Oct 2025AY 2013-14

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekdcit, Ltu, Circle 1 & 2, Vs. India Yamaha Motor Pvt. Ltd., 1St Floor, Great Eastern Centre, New Delhi. 70, Nehru Place, Ifci Tower, New Delhi – 110 019. (Pan : Aabci7552F) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Revenue By : Shri Dharm Veer Singh, Cit Dr Date Of Hearing : 09.10.2025 Date Of Order : 09.10.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals),-44, New Delhi [For Short ‘Ld. Cit (A)] Dated 29.06.2018 For Assessment Year 2013-14. 2. At The Time Of Hearing, Ld. Ar For The Assessee Submitted That Since The Assessee Has Settled The Issue Under Vivad Se Vishwas Scheme, 2024 (In Short ‘Vsvs’), Hence, The Appeal Filed By The Revenue Has Become Infructuous & Deserves To Be Dismissed As Infructuous. In This Regard

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR

time of hearing, ld. AR for the assessee submitted that since the assessee has settled the issue under Vivad Se Vishwas Scheme, 2024 (in short ‘VSVS’), hence, the appeal filed by the Revenue has become infructuous and deserves to be dismissed as infructuous. In this regard