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Settlement & AmnestyDTVSV 2020DTVSV 2020198 judgments

AKSHAJ ENTERPRISES LLP ,MUMBAI vs. ITO WARD 17(1)(1), MUMBAI

In the result Assessee’s Appeal is allowed for statistical purposes

ITA 6885/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19

For Appellant: Ms. Mokhsa Mehta, Ld. AR (virtual)For Respondent: Shri Surendra Mohan, Ld. SR. DR
Section 250

A.Y.2018-19. 2. In this case, the Ld. Counsel for the Assessee demonstrated the fact that the Assessee has filed Form No.1 under DTVSV Scheme 2024 for the Assessment Year 2022-23, which ultimately resulted into issuing the Form No.4 and making the payment as well. 3. Further, the Ld. Counsel ... screen shot of e-filing portal of the Department (page No.25 of paper book) where from it clearly appears that the declaration under DTVSV Scheme 2024 has been filed and/or available only for Assessment Year 2022-23.Thus,the Ld. Counsel for the Assessee has claimed that no such Form under DTVSV

BILIYA SEVA SAHKARI MANDLI LIMITED,MORBI, RAJKOT vs. ITO WARD 1, MORBI, MORBI

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

ITA 742/RJT/2025[2018-19]Status: DisposedITAT Rajkot29 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 742/Rjt/2025 Assessment Year: (2018-19) Biliya Seva Sahkari Mandli Vs. Income Tax Office, Aayakar Limited Vibhag, J.K. Chamber, National At. Biliya, Tal. Morbi, Gujarat, Highway-8-A, At- Lalpar, Morvi 363641 (Gujarat) Morbi 363642 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabab3498H (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. A.RFor Respondent: Shri Gopi Nath Chaubey, Ld. Sr. DR
Section 147Section 234ASection 234FSection 253(5)Section 270ASection 80P(2)(d)

submitted that the Ld. CIT(A) has wrongly dismissed the appeal, on the ground that the assessee has chosen to settle the dispute through DTVSV scheme “The Direct Tax Vivad Se Vishwas Scheme- 2024” while the assessee has no submitted any withdraw letter to the Ld. CIT(A) However

ICRA LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10(1), CR BUILDING, IP ESTATE, DELHI

In the result, A.Y.2013-14 of Revenue’s appeal is dismissed and Assessee’s appeals for A

ITA 2723/DEL/2025[2020-21]Status: DisposedITAT Delhi28 Jan 2026AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 14ASection 37(1)

which includes the issue in respect of disallowance u/s. 14A r.w.r. 8D of IT Rules. The Ld. Counsel submitted that pending application under DTVSV Scheme, 2020 the assessee has withdrawn its appeal before the Ld. CIT(A) vide letter dated 30.03.2021. On 14.09.2022 the Ld. CIT(A) dismissed the appeal ... assessee as withdrawn since the disputes in appeal was settled under DTVSV Scheme, 2020. 12. The Ld. Counsel for the assessee submitted that after settling the issues/disputes under DTVSV Scheme, a notice u/s.154 was issued by the AO proposing to enhance the income of the assessee assessed u/s.143

ICRA LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10(1), CR BUILDING, IP ESTATE, DELHI

In the result, A.Y.2013-14 of Revenue’s appeal is dismissed and Assessee’s appeals for A

ITA 2722/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 14ASection 37(1)

which includes the issue in respect of disallowance u/s. 14A r.w.r. 8D of IT Rules. The Ld. Counsel submitted that pending application under DTVSV Scheme, 2020 the assessee has withdrawn its appeal before the Ld. CIT(A) vide letter dated 30.03.2021. On 14.09.2022 the Ld. CIT(A) dismissed the appeal ... assessee as withdrawn since the disputes in appeal was settled under DTVSV Scheme, 2020. 12. The Ld. Counsel for the assessee submitted that after settling the issues/disputes under DTVSV Scheme, a notice u/s.154 was issued by the AO proposing to enhance the income of the assessee assessed u/s.143

ICRA LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10(1), CR BUILDING, IP ESTATE, DELHI

In the result, A.Y.2013-14 of Revenue’s appeal is dismissed and Assessee’s appeals for A

ITA 2721/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Jan 2026AY 2017-18

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 14ASection 37(1)

which includes the issue in respect of disallowance u/s. 14A r.w.r. 8D of IT Rules. The Ld. Counsel submitted that pending application under DTVSV Scheme, 2020 the assessee has withdrawn its appeal before the Ld. CIT(A) vide letter dated 30.03.2021. On 14.09.2022 the Ld. CIT(A) dismissed the appeal ... assessee as withdrawn since the disputes in appeal was settled under DTVSV Scheme, 2020. 12. The Ld. Counsel for the assessee submitted that after settling the issues/disputes under DTVSV Scheme, a notice u/s.154 was issued by the AO proposing to enhance the income of the assessee assessed u/s.143

ICRA LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-10(1), CR BUILDING, IP ESTATE, DELHI

In the result, A.Y.2013-14 of Revenue’s appeal is dismissed and Assessee’s appeals for A

ITA 2720/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Jan 2026AY 2013-14

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 14ASection 37(1)

which includes the issue in respect of disallowance u/s. 14A r.w.r. 8D of IT Rules. The Ld. Counsel submitted that pending application under DTVSV Scheme, 2020 the assessee has withdrawn its appeal before the Ld. CIT(A) vide letter dated 30.03.2021. On 14.09.2022 the Ld. CIT(A) dismissed the appeal ... assessee as withdrawn since the disputes in appeal was settled under DTVSV Scheme, 2020. 12. The Ld. Counsel for the assessee submitted that after settling the issues/disputes under DTVSV Scheme, a notice u/s.154 was issued by the AO proposing to enhance the income of the assessee assessed u/s.143

SOLENIS CHEMICALS INDIA PRIVATE LIMITED,ANKLESHWAR vs. ASSESSMENT UNIT (JAO ASSISTANT COMMISSIONER OF INCOME TAX - 1(3)(1), MUMBAI), 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)

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. No. 4718/Mum/2024 • received Form No. 2 dated 18/12/2025, issued by the designated authority, determining a refund

VIJAYARANGAM RANGANATH PRAVHAKAR,BENGALURU vs. ACIT, CIRCLE-4(3)(1), BANGALORE

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

ITA 164/BANG/2025[2017-18]Status: DisposedITAT Bangalore15 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR
Section 129Section 142(1)Section 143(2)Section 269SSection 271Section 271DSection 274

about the order passed by the Ld.CIT(A). The assessee further submitted that when the assessee was intended to settle the issue under the DTVSV Scheme, 2024 and the auditor viewed the portal to know the status of the appeal and then only the assessee came to know about

VIKASH AGARWAL,KOLKATA vs. I.T.O., WARD - 61(3), KOLKATA

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

ITA 1896/KOL/2024[2014-2015]Status: DisposedITAT Kolkata10 Dec 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 250Section 91(2)Section 91(3)Section 92(2)

outset, it was informed by the Ld. AR that the assessee has availed the Direct Tax Vivad se Vishwas Scheme, 2024 (in short the ‘DTVSV Scheme’) and Form-2 dated 18.02.2025 has also been received by the assessee and the due taxes have been paid. Since the assessee has opted ... DTVSV Scheme, the present appeal becomes infructuous and needs to be withdrawn, it was stated by the Ld. AR. The Ld. DR did not object to the withdrawal of the appeal. I.T.A. No.: 1896/KOL/2024 Assessment Year: 2014-15 Vikash Agarwal. 3. As per S. No. 10 of the Guidance Note

M/S ANDAZ TRADING & INFRASTRUCTURE PVT LTD,MUMBAI vs. ITO -WARD 4(1)(3), MUMBAI

In the result, the appeal is allowed for statistical purposes

ITA 5841/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Acccountant Member

For Appellant: Ms. Ruchi RathodFor Respondent: Shri. Surendra Mohan, Sr. DR
Section 143(3)Section 250Section 271DSection 40Section 43BSection 43C

passed under Section 143(3) of the Act, on the erroneous premise that the Appellant had opted for withdrawal of the appeal under the DTVSV Scheme, 2020, although no such withdrawal was ever made in respect of the said assessment appeal. 2. On the facts and in the circumstances ... case and in law, the CIT(A) failed to appreciate that the Appellant had opted for the DTVSV Scheme, 2020 only in respect of the penalty appeals arising out of orders under Sections 271D and 271E of the Act, and not in respect of the appeal against the Assessment Order

PRABODH CENTRE FOR RURAL REFORMS,PUNE vs. CIT(EXEMPTION), PUNE, 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)

r.w.s.93 of Finance (No.2) Act, 2024 has certified the full and settlement of Tax Arrear as per the application filed by the assessee under DTVSV scheme which has been calculated on the additions made by ld. AO and it therefore shows that ld.CIT(Exemption) has accepted the income assessed

DINESH CHAND MAHESHWARI,MEERUT vs. ACIT, CIRCLE-1(1)(1), MEERUT

Appeal is dismissed as withdrawn in above terms subject to all just exceptions

ITA 179/DEL/2025[2014-15]Status: DisposedITAT Delhi10 Nov 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 179/Del/2025 : Asstt. Year : 2014-15 Dinesh Chand Maheshwari, Vs Acit, Maheshwari Associates, Rithani Delhi Circle-1(1)(1), Road, Meerut-250002 Meerut-250002 (Appellant) (Respondent) Pan No. Aajpc0109R Assessee By: None Revenue By : Sh. Jitender Singh, Cit-Dr Date Of Hearing: 10.11.2025 Date Of Pronouncement: 10.11.2025 Order Per Satbeer Singh Godara:

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT-DR
Section 147

appellant (where he has declared that he has decided to withdraw appeal sumoto), and Form No. 3 and Form No. 4 under the DTVSV Scheme 2024 are also enclosed herewith. Now it may kindly request you and pray before your honour please allow the appellant to withdraw the appeal

3M INDIA LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 168/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Sept 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Ms. Shruti Agarwal, A.RFor Respondent: Dr. Divya K.J., D.R
Section 143(3)Section 91(2)Section 92Section 92(1)

have heard the rival submissions and perused the materials available on record. As per the provisions of section 91(2) of the DTVSV Scheme, 2024, any appeal pending before the ITAT or CIT(A) in respect of disputed interest or disputed penalty or disputed fee or tax arrears shall ... deemed to have been withdrawn upon the issuance of certificate u/s 92(1) of the DTVSV Scheme, 2024. 5.1 On going through the letter along with the enclosures filed on 18.07.2025, we find that the Form No.2 i.e. Certificate under sub- section (1) of section 92 of the Finance

QUINTILES INC.,MUMBAI vs. DCIT (IT) CIR 3(3)(1), MUMBAI

In the result, appeals filed by the assessee are dismissed as withdrawn

ITA 728/MUM/2017[2013-14]Status: DisposedITAT Bangalore09 Sept 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2012-13

For Appellant: NONEFor Respondent: Dr. Divya K.J., D.R
Section 143(3)Section 91(2)Section 92Section 92(1)

have heard the rival submissions and perused the materials available on record. As per the provisions of section 91(2) of the DTVSV Scheme, 2024, any appeal pending before the ITAT or CIT(A) in respect of disputed interest or disputed penalty or disputed fee or tax arrears shall ... deemed to have been withdrawn upon the issuance of certificate u/s 92(1) of the DTVSV Scheme, 2024. IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore Quintiles Inc., Mumbai Page 3 of 3 5.1 On going through the letters along with the enclosures filed on 17.2.2025, we find that

QUINTILES INC.,MUMBAI vs. DCIT (INTL. TAX) RANGE 3(3)(1), MUMBAI

In the result, appeals filed by the assessee are dismissed as withdrawn

ITA 2104/MUM/2016[2012-13]Status: DisposedITAT Bangalore09 Sept 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2012-13

For Appellant: NONEFor Respondent: Dr. Divya K.J., D.R
Section 143(3)Section 91(2)Section 92Section 92(1)

have heard the rival submissions and perused the materials available on record. As per the provisions of section 91(2) of the DTVSV Scheme, 2024, any appeal pending before the ITAT or CIT(A) in respect of disputed interest or disputed penalty or disputed fee or tax arrears shall ... deemed to have been withdrawn upon the issuance of certificate u/s 92(1) of the DTVSV Scheme, 2024. IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore Quintiles Inc., Mumbai Page 3 of 3 5.1 On going through the letters along with the enclosures filed on 17.2.2025, we find that

H- COMPUTER SERVICES AND MANPOWER CONSULTANCY ,NALGONDA vs. INCOME TAX OFFICER, WARD-1, NALGONDA

ITA 648/HYD/2023[2018-19]Status: DisposedITAT Hyderabad26 Aug 2025AY 2018-19

Bench: THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, HYDERABAD

Section 143(3)Section 92

requested to withdraw the appeal. Also, we find that the aforesaid letter dated 25.08.2025 is accompanied by (i) Form 1 - Declaration under DTVSV Scheme, 2024; and (ii) Form 2 i.e. Certificate under sub-section (1) of Section 92 of the Finance (No.2) Act, 2024. For the sake of clarity ... under : -left blank intentionally- 3 H-Computer Services and Manpower Consultancy 3. Considering the fact that the assessee firm had opted for DTVSV Scheme, 2024, we herein dismiss the captioned appeal as withdrawn. Before parting, we may herein observe that in case, if for any reason, the captioned appeal

DEEPAK KUMAR SAHA,BARPETA vs. ACIT CIR-2, GUWAHATI, GUWAHATI

In the result, the appeals of the assessee is allowed for statistical purposes only

ITA 76/GTY/2025[2017-18]Status: DisposedITAT Guwahati21 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Manomohan Das, Hon’Ble

For Appellant: Shri S.P. Bhati, FCAFor Respondent: Shri Kaushik Ray, JCIT
Section 115BSection 133ASection 250Section 5

disputed fee and tax arrears shall be deemed to have been withdrawn from the date on which, certificate under sub-section 5 of the DTVSV Scheme, 2020. Accordingly, the ld. CIT(A) dismissed the appeal of the assessee as infructuous. 6. We observe that, the assessee challenged the order passed

GUMMADI SARASWATHI,TENALI vs. INCOME TAX OFFICER, WARD-1, TENALI

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

ITA 375/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 375/Viz/2025 (A.Y. 2016-17) Gummadi Saraswathi V. Income Tax Officer - Ward – 1 C/O. Ca Mv Prasad Income Tax Office First Floor D.No. 19-15-47 Opposite Prasad & Co Contractors Opp. Sai Baba Temple D.No. 6-3-871, Snehalata Tenali – 522201 Greenlands Road, Begumpet Andhra Pradesh Hyderabad – 500016 [Pan:Amapg7100K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 147Section 263Section 56(2)(vii)

property u/s.56(2)(vii) of the I.T. Act. The appellant has preferred an appeal before Learned CIT(Appeals). Meanwhile the appellant has opted for DTVSV Scheme and accordingly filed Form No.1 before the Jurisdictional Pr.CIT, Vijayawada. However, during such time, the assessment has been reopened u/s.263 ... till the proceedings u/s. 263 initiated by the Pr.CIT are closed. She thought that after finalization of the 263 proceedings and consequent assessment, the DTVSV Scheme will be applicable and waited for such orders. However, the application was rejected by the Pr.CIT stating that the proceedings u/s.263

LOKMANGAL CO-OPERATIVE BANK LTD.,SOLAPUR vs. ASST. COMMISSIONER OF INCOME TAX OFFICE CIRCLE - 2 , SOLAPUR

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

ITA 1179/PUN/2024[2015-16]Status: DisposedITAT Pune07 Aug 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1179/Pun/2024 धििाारण वर्ा / Assessment Year: 2015-16 Lokmangal Co-Operative Asstt. Cit, Circle-2, Bank Ltd, Solapur 128, Murarji Peth, Near Vs. Sevasadan, High School, Solapur-413001 Maharashtra Pan-Aaaal0119J अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Ca Pramod Shingte Department By: Shri Ramnath P Murkunde Date Of Hearing: 07-08-2025 Date Of 13-08-2025 Pronouncement:

For Appellant: CA Pramod ShingteFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 250

Income Tax Department has issued Form No. 2 specifying the balance amount of tax payable by the assessee under the DTVSV Scheme. Considering the application/contention of the assessee the instant appeal is dismissed as withdrawan on account of the application being addmitted under DTVSV Scheme, 2024. We however grant liberty ... calling of this order in case the assessee is unable to get Form No. 4 from the Income Tax Department and application under DTVSV Scheme, 2024 is rejected. Accordingly appeal of the assessee is dismissed as withdrawn. 5. In the result, appeal of the assessee is dismissed as withdrawn. Order

BADRI NARAYAN CHOUDHARY,JAIPUR vs. ITO WARD 4(1), JAIPUR

In the result, the appeal of the assessee is allowed

ITA 341/JPR/2025[2010-2011]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-2011

Bench: Or Before Hearing Of This Appeal.”

For Appellant: Sh. Ashish Khandelwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 271ASection 271BSection 4Section 44A

case in treating deemed withdrawal of appeal as per clause 2 of section 4 of DTVSV Act 2020 even when appellant never opted for DTVSV scheme are filed any application for withdrawal. 2. That the lower authorities have erred in law as well in facts is imposing/confirming penalty u/s 271B

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