“direct tax vivad se vishwas”

Settlement & AmnestyDTVSV 2020DTVSV 20202,154 judgments

Judgments citing direct tax vivad se vishwas

Shankaranarayana Constructions Private Limited, Sns House, Residency Road vs. Asst. Commissioner of Income Tax, Central Circle 2(4), Central Revenue Building, Queens Road, Bengaluru

In the result, this portion of appeal is partly allowed for statistical purposes

ITA 1268/BANG/2025[2015-2016]Status: DisposedITAT Bangalore26 Nov 2025AY 2015-2016

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

Section 132Section 143Section 14ASection 153ASection 250

well as this Tribunal. Later on, pending the appeal before the Hon’ble High Court, the assessee settled the matter under the Direct Tax Vivad Se Vishwas Scheme, 2024. Page 14 of 19 ITA Nos. 1268 to 1271/Bang/2025 11. Similarly, the AO had disallowed the amortisation of cost of building

Levin Detha, Jodhpur vs. ACIT, Circle-1, Jodhpur

In the result, the appeal in ITA No

ITA 470/JODH/2024[2017-18]Status: DisposedITAT Jodhpur25 Nov 2025AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon'Ble & Dr. S. Seethalakshmi, Hon'Ble

application dated 07/01/2025 had requested to withdraw the instant appeal stating therein that "I am willing to avail the benefit of the Direct Tax Vivad se Vishwas Scheme, 2024 provided under Chapter IV of the Finance (No.2) Act, 2024 (15 of 2024) do hereby voluntarily file this application for withdrawal

John Deere India Pvt.Ltd, Pune vs. Deputy Commissioner of Income Tax, Pune

In the result, appeal of the Assessee is dismissed as

ITA 1165/PUN/2017[2012-13]Status: DisposedITAT Pune24 Nov 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Prakash L Pathade, CIT-DR

Section 143(3)Section 250Section 91(3)

assessee has filed an application for withdrawal of the instant appeal pursuant to settling of tax dispute under Direct Tax Vivad Se Vishwas Scheme, 2024 (VSV Scheme, 2024). It is submitted that assessee has received Form No.2, dated 29/10/2025, determining the tax liability under VSV Scheme, 2024 and pursuant

Prabodh Centre for Rural Reforms, Pune vs. CIT(Exemption), Pune

In the result, the appeal filed by the assessee is allowed as per terms indicated herein above

ITA 1225/PUN/2025[2020-21]Status: DisposedITAT Pune14 Nov 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1225/Pun/2025 Assessment Year : 2020-21 Prabodh Centre For Rural Reforms, Vs. Cit (Exemption), Gat No.143, Village Bhukum, Pune Tal. Mulshi, Pune 411042 Maharashtra Pan : Aadtp6064A Appellant Respondent

For Appellant: Shri Abhay AvchatFor Respondent: Shri Amit Bobde

Section 11(5)Section 143(2)Section 143(3)Section 263Section 92(2)

income from impermissible investments and the same charged to tax at the Maximum Marginal Rate. Assessee moved an application under the Direct Tax Vivad Se Vishwas Scheme (DTVSV) and even paid the disputed tax amount of Rs.1,83,533/- and Form No.4 was also issued by ld.CIT(Exemption, Pune

Rekha Ajit Chaudhari, Pune vs. Ward 3(3), Pune

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

ITA 2069/PUN/2025[2013-14]Status: DisposedITAT Pune10 Nov 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2069/Pun/2025 Assessment Year 2013-14

For Appellant: NoneFor Respondent: Shri Vinod Pawar

Section 142(1)Section 144Section 147Section 148Section 69

Investments made in the form of Fixed Deposits are to be shared by assessee and other legal heirs. Further, assessee has opted Direct Tax Vivad se Vishwas Scheme and Form Nos. 4 and 5 are awaited. Therefore, it is contended that that notice u/s.148 is unwarranted

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

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 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

Satyam Transformers Private Limited, Aurangabad vs. ITO Ward 2(3), Aurangabad

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

ITA 1239/PUN/2025[2015-16]Status: DisposedITAT Pune27 Oct 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1239/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 Satyam Transformers Private Limited, Ito, Ward-2(3), Sharadanand, Opposite Telephone Office, Aurangabad Ajabnagar, Aurangabad-431001 Vs. Pan : Aakcs4648D अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi Department By : Shri Akhilesh Srivastva Date Of Hearing : 04-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Akhilesh Srivastva

Section 143(2)Section 143(3)Section 250Section 72

letter dated 12.01.2021stated that it had applied for settlement of this dispute under VSVS scheme. 2020 (as per provisions of the Direct Tax Vivad se Vishwas Act. 2020). Therefore, the appellant requested for withdrawal of its appeal to avail the benefit of the scheme. For the sake of clarity ... therefore deserves to be allowed.” 6. The Ld. AR submitted that the assessee’s application under the Direct Tax Vivad Se Vishwas Act, 2020 (“DTVSV Act, 2020”) has been rejected by the Income Tax Department. Admittedly, there was a lapse on the part of the assessee to inform

Surjit Singh Amrik Singh Saini, Mumbai vs. Dict, Circle 27(3), Mumbai

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

ITA 2419/MUM/2024[2018-19]Status: DisposedITAT Mumbai15 Oct 2025AY 2018-19

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarsurjit Singh Amrik Singh Saini, Chacha House, Chembur Mumbai – 400071, Maharashtra ............... Appellant Pan: Alzps4719C V/S Dcit, Circle-27(3), Ito, Vasi Railway Station Building, ……………… Respondent Navi Mumbai

For Appellant: Shri Bipin KothariFor Respondent: Shri Swapnil Choudhary, Sr. DR

Section 250

permission to withdraw the appeal on the basis that the tax dispute for the 2 year under consideration has been settled under Direct Tax Vivad Se Vishwas Scheme, 2024 and the order for full and final settlement in Form no.4 has been issued by the Designated Authority after payment

Karnail Singh Uppal, Phillaur vs. ITO-2, Phagwara

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

ITA 189/ASR/2024[2011-12]Status: DisposedITAT Amritsar13 Oct 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: (3) The CIT concerned

Section 250Section 92(1)

assessee has filed written request for withdrawal of the appeal due to the reasons that they have filed application under “Direct Tax Vivad Se Vishwas Scheme- 2024”, for settlement of disputes relating to tax arrears, in respect of the assessment year stated above. 3. Documentary evidence in Form-4 (rule

Ravindra Jaisingrao Chavan, Aurangabad, Maharashtra vs. ACIT, Central Circle 1, Aurangabad, Maharashtra

In the result, the appeal filed by the assessee is allowed for statistical purposes as per terms indicated hereinabove

ITA 1109/PUN/2025[2021-22]Status: DisposedITAT Pune06 Oct 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Vardhaman L. JainFor Respondent: Shri Amit Bobde

Section 131Section 133ASection 142(1)Section 143(3)Section 263

PCIT. We also notice that in the paper book page Nos.171 to 193 assessee has filed a copy of declaration under the Direct Tax Vivad Se Vishwas Scheme and Form No.2 refers to the Tax Arrear of Rs.3,73,53,478/- and Form No. 3 has been issued

Asst. Commissioner of Income Tax, Central Circle, Muzaffarpur vs. Ajit Kumar, Bettiah

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

ITA 239/PAT/2024[2017]Status: DisposedITAT Patna29 Sept 2025

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 143(3)Section 148Section 250Section 40A(3)Section 69

dismissed. 10. A query was made as to whether once the assessee has opted for Direct Tax Vivad se Vishwas Scheme, 2024 (in short ‘VSV Scheme’), the Revenue can continue with this appeal, to which the Ld. DR pointed out that in the present scheme partial declaration under VSV Scheme

High Profile Softech Pvt Ltd, U.P vs. ITO, Ward-11(1), Delhi

ITA 4821/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Sept 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19

Section 147

Case file perused. 2. The assessee submits before the bench at the outset that it has already opted for settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024 and also received Form 4 dated 14.5.2025 from the competent authority as well. And that it had also filed application dated ... vide acknowledgment no 116308530140423 and Appeal Reference No. NFAC/2017-18/10236586. In this regard, it is submitted that the assessee has applied under Direct Tax Vivad Se Vishwas Act, 2024 vide it's application acknowledgement number 774242930261224 dated 26.12.2024 of Form no 1&2 and subsequently received Form 3 from the Income

Ramesh Nanjundiah Devaryasamudram, Jaipur vs. Income Tax Officer 2(1), Bhopal

The appeal is hereby DISMISSED AS WITHDRAWN

ITA 256/IND/2025[2010-11]Status: DisposedITAT Indore26 Sept 2025AY 2010-11

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2010-11 Ramesh Nanjundiah Ito 2(1) Devaryasamudram, Bhopal 101, Ground Floor, बनाम/ Plot No.7, Pooja Vihar, Vs. Sirsi Road Bishnawal, Jhotwara, S.O. Jaipur (Assessee/Appellant) (Revenue/Respondent) Pan: Adupd0388H Assessee By Shri Manoj Fadnis, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 22.09.2025 Date Of Pronouncement 26.09.2025

Section 143(3)Section 154Section 250Section 271(1)(c)

Addl/JCIT (A)-2, Nagpur has dismissed the appeal as withdrawn by erroneously considering Form 4 and 1 Form 5 of Direct Tax Vivad se Vishwas Scheme, 2020 filed in the case of penalty appeal u/s 271(1)(c) to the appeal filed u/s 143(3) of the act. 2.That since ... claim the benefits of VSVS 2020. In view of the above, the appeal is being decided as per provisions of the Direct Tax Vivad Se Vishwas (DTVSVS) Act, 2020. It is also noted that the Page 3 of 5 Ramesh Nanjundiah Devarayasamudram ITA No. 256/Ind/2025 - AY 2010-11 Form

Syed Rafat Zubair Rizvi, Lucknow vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi

In the result, the appeal of the assessee is dismissed

ITA 383/LKW/2024[2015-16]Status: DisposedITAT Lucknow26 Sept 2025AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Syed Zubair Rizvi, Vs. Commissioner Of Income Tax 1, Kaiserbagh Avenue, Lucknow, (Appeals), Nfac, Delhi Uttar Pradesh Pan: Ajvps4151L (Appellant) (Respondent) Assessee By: Sh. Aleem Khan, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 24.09.2025 Date Of Pronouncement: 26.09.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit Nfac, Dated 26.3.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Against The Orders Of The Ld. Ao Passed Under Section 147 R.W.S. 144 On 19.11.2019. The Grounds Of Appeal Are As Under:- “1. Because Appellant Has Filed Return Of Income On 19.08.2015 For Ay 2015-16 Vide Acknowledgment No.649289701140618 Showing Total Income Of Rs.1,10,51,960/- 2. Because Appellant Sold 14Flats, 2Shops & 2Lands In Assessment Year 2015-16 The Said Building Was Constructed In The Year 2005-06 As A Commercial Building Knows As Essaar Mall. But Due To Local Factors Assessee Failed To Sold His Premises & After Many Years Of Failure He Decided To Convert The Same Into Residential Building & The Flats Were Constructed In The Year 2013. Due To Blockage Of Fund & Non-Sale Of Flats Assessee Sold At The Lower Rate Approval Of Residential Construction Form The Up Awas Evam Vikas Parishad Was Also Obtained Before Converting The Commercial Construction To Residential. 3. Because An Addition Of Rs.87,46.596/- Is Made By Ld. Assessing Officer On The Basis Of Valuation Report Vide Letter F.No.1200To 1213/Avo/Itd/Lko/2017-18/872 Dated 19.03.2018 Which Was Sustained By Learned Commissioner Of Income Tax (Appeals), Income Tax Department, Nfac

For Appellant: Sh. Aleem Khan, AdvFor Respondent: Sh. Amit Kumar, DR

Section 147Section 43C

assessee filed an affidavit signed by the assessee in which it was submitted that the assessee had opted for the Direct Tax Vivad Se Vishwas Scheme, 2024 and therefore, he had voluntarily decided to withdraw the aforesaid appeal pending before the Tribunal. The ld. AR submitted before us that Form ... assessee as withdrawn, subject to liberty to the assessee to re-approach the Tribunal, in case the settlement of the dispute under Direct Tax Vivad Se Vishwas Scheme, 2024, is not completed for any reason. 5. In the result, the appeal of the assessee is dismissed. Order pronounced

DCIT Circle 1(1)(1), Mumbai vs. Aegis Logistics Limited, Mumbai

In the result, the appeal of the Revenue is allowed partly for

ITA 4944/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Sept 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Abdulkadir JawadwalaFor Respondent: Mr. Surendra Mohan, Sr. DR

Section 143(1)Section 14A

Board of Direct Taxes (CBDT); (c) engagement in a special drive initiated by the CBDT to complete orders giving effect to the Direct Tax Vivad Se Vishwas Scheme, 2020; and (d) technical difficulties encountered on the income-tax portal, particularly the non-receipt of the one-time password

Giza Builders & Developers Pvt. Ltd., New Delhi vs. ITO, Ward- 11(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 7274/DEL/2018[2009-10]Status: DisposedITAT Delhi26 Sept 2025AY 2009-10

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2009-10] Giza Builders & Developers Income Tax Officer, Pvt. Ltd., Ward- 11(2), (Now Merged With M/S Karida Vs Cr Building, Real Estates Pvt. Ltd.) New Delhi. Seating 4, Unit No.- 119, First Floor, Vardhman Star City Mall, Sector-7, Dwarka, New Delhi-110075. Pan- Aaccg7585M Assessee Revenue

Section 143(3)Section 144Section 147Section 201Section 201(1)Section 40

assessee has relied upon Question no. 31 of CBDT Circular no. 7/2020 dated 04.03.2020, on the subject- ‘Clarifications on provisions of Direct Tax Vivad Se Vishwas Bill, 2020’. The relevant extract of the clarification is reproduced as under: “Question no. 31. Where assessee settles TDS liability as deductor

Vinay Kumar Bhuwania, New Delhi vs. ACIT, Circle-6(2), New Delhi

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

ITA 7892/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Sept 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2014-15] Binay Kumar Bhuwania, Commissioner Of Income Tax 1001 Aakash Deep Building, (Appeals)-2, 26-A, Barakhamba Road, Vs Hall No. 1, Room No. -102, Connaught Place, New Delhi- Aakyar Bhawan, Laxmi 110001. Nagar District Centre, Delhi-110092. Pan- Aadpb1134F Assessee Revenue

Section 143(3)

matter was called for hearing, the Ld. AR for the assessee submitted that the assessee has settled this appeal under the Direct Tax Vivad se Vishwas Scheme, (DTVSVS) and submitted Form 5 under DTVSVS 2020. The Ld. AR further stated that the assessee does not wish to pursue the present ... sought on behalf of the assessee. 5. In view of above fact, since the assessee has availed the benefit under to Direct Tax Vivad se Vishwas Scheme, the assessee is allowed to withdraw his appeal. If at any stage the assessee finds that its declarations are not accepted by Department

Gudipudi Venkateswara Rao, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

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

ITA 473/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No. 473/Viz/2024 (धनिाारण िर्ा / Assessment Year: 2017-18) Gudipudi Venkateswara Rao, Vs. Income Tax Officer, Guntur. Ward-1(1), Pan: Ayfpg4742A Guntur. (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Assessee By : None प्रत्यार्थी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar सुनिाई की तारीख / Date Of Hearing : 08/09/2025 घोर्णा की तारीख/Date Of : 24/09/2025 Pronouncement O R D E R

For Appellant: NoneFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 271DSection 92Section 93

settlement of tax arrears under sub-section (2) of section 92 read with section 93 of Finance (02) Act, 2024 (under the Direct Tax Vivad Se Vishwas Scheme, 2024). The Ld. DR also did not raise any objection. Therefore, we are of the considered view that the appeal

M/S Hero Investment Pvt. Ltd., Ludhiana vs. ACIT Circle-5, Ludhiana

In the result, appeal of the Assessee is dismissed

ITA 353/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh23 Sept 2025AY 2011-12

Bench: Your Honour Being Infructuous.”

For Appellant: Shri Ashish Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT DR

humbly submitted that the issue involved in the original assessment proceedings has been settled by the assessee company though Direct Tax Vivad Se Vishwas Scheme, 2020. Therefore, we wish to withdraw this appeal before your Honour being infructuous.” 3. Ld. DR did not object if the appeal of the assessee

3M India Ltd vs. ACIT

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

ITA 1635/BANG/2013[2008-09]Status: DisposedITAT Bangalore18 Sept 2025AY 2008-09

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

For Appellant: NoneFor Respondent: Shri Shashi Saklani, CIT-DR

assessee furnished a letter dated 09/09/2025 in which the assessee had submitted that they filed an application in form 1 under the Direct Tax Vivad se Vishwas Scheme, 2024 on 30/04/2025 and thereafter the PCIT, Bangalore also issued a certificate in form 2. In the said letter, the assessee sought