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“vsv scheme”

Settlement & AmnestyDTVSV 2020DTVSV 2020524 judgments

Judgments citing vsv scheme

DCIT, Circle-21(1), New Delhi vs. Ranjitgarh Finance Co. P.Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 7555/DEL/2018[2014-15]Status: DisposedITAT Delhi19 Dec 2024AY 2014-15

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumar[Assessment Year : 2014-15] Dcit Vs Ranjitgarh Finance Co.P.Ltd. Circle-21(1) Lp-11 C Pitampura New Delhi. New Delhi-110034. Pan-Aabcr8108C Appellant Respondent Appellant By Ms. Harpreet Kaur Hansra, Sr. Dr Respondent By Shri Mukesh Sukhija, Adv. Date Of Hearing 19.12.2024 Date Of Pronouncement 19.12.2024 Order Per Pradip Kumar Kedia, Am : The Instant Appeal Has Been Filed At The Instance Of The Revenue Seeking To Assail The First Appellate Order Dated 04.09.2018 Passed By Ld. Commissioner Of Income Tax(A)-7, New Delhi [“Ld.Pr. Cit”] U/S 250(6) Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014- 15. 2. When The Matter Was Called For Hearing, The Ld. Counsel For The Assessee Submitted That As Per The Instruction Of The Client, The Assessee Is Opting For The Ongoing “The Direct Tax Vivad Se Vishwas (Dtvsv) Scheme, 2024”. The Learned Counsel Thus Submitted That The Assessee Does Not Seek To Pursue The Said Appeal Owing To Exercise Of Option For Availing Dtvsv Scheme & Consequently Requested That The Written Application For Withdrawal Of Appeal May Please Be Granted.

Section 143(3)Section 250(6)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “F” BENCH: NEW DELHI BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI VIMAL

Shivlal, Bengaluru vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

In the result, both the appeals filed by the assessee are dismissed as withdrawn

ITA 1372/BANG/2024[2015-16]Status: DisposedITAT Bangalore12 Dec 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Suman Lunkar, A.RFor Respondent: Shri Ganesh R Gale, Standing counsel for department
Section 250

ITA No.1371&1372/Bang/2024 Shivlal, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER

Shivlal, Bengaluru vs. The Deputy Commissioner Income Tax, Central Circle-1(3), Bengaluru

In the result, both the appeals filed by the assessee are dismissed as withdrawn

ITA 1371/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Dec 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Suman Lunkar, A.RFor Respondent: Shri Ganesh R Gale, Standing counsel for department
Section 250

ITA No.1371&1372/Bang/2024 Shivlal, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER

Bucher Hydraulics Private Limited, Gurgaon vs. DCIT, Circle-4(2), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 799/DEL/2022[2011-12]Status: DisposedITAT Delhi12 Dec 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Anubhav Sharmabucher Hydraulics Pvt. Ltd, Vs. Dcit, Plot No. 6, Sector-5, Imt Circle-4(2), Manesar, Gurugaon, New Delhi Haryana (Appellant) (Respondent) Pan: Aaecs5991H

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri Mathew Jacob, Sr. DR
Section 143(3)Section 4Section 91(1)Section 91(4)

wherein the Hon‟ble High Court after considering the intention of the assessee to avail the benefit of „Vivad se Vishwas Scheme-2020‟ (VSV scheme), had dismissed the appeal by observing in Para 7 to 9 as under:- “7. As observed, the assessee is given liberty to restore this appeal

Satish Chandra, Solan vs. Assistant Commissioner of Income Tax, Noida

In the result, the appeals of the assessee are dismissed as withdrawn

ITA 46/DEL/2024[ay 2014-15]Status: DisposedITAT Delhi10 Dec 2024

Bench: Shri Satbeer Singh Godara & Shri Pradip Kumar Kedia&

Section 250Section 271(1)(c)Section 43BSection 54

learned Counsel thus submitted that the assessee does not seek to pursue the said appeals owing to exercise of option for availing VSV Scheme and consequently requested that the written application for withdrawal of appeals may please be granted. 4. The Ld. Sr. DR for the Revenue stated that ... behalf of the assessee, the captioned appeals are dismissed as withdrawn. However, in the event, the assessee fails to avail the benefit of VSV Scheme for any bonafide reasons, then the assessee concerned shall be at liberty to seek restoration of original appeals for hearing before ITAT in accordance with

Satish Chandra, Solan vs. Assistant Commissioner of Income Tax Circle 3, Noida

In the result, the appeals of the assessee are dismissed as withdrawn

ITA 45/DEL/2024[AY 2014-15]Status: DisposedITAT Delhi10 Dec 2024

Bench: Shri Satbeer Singh Godara & Shri Pradip Kumar Kedia&

Section 250Section 271(1)(c)Section 43BSection 54

learned Counsel thus submitted that the assessee does not seek to pursue the said appeals owing to exercise of option for availing VSV Scheme and consequently requested that the written application for withdrawal of appeals may please be granted. 4. The Ld. Sr. DR for the Revenue stated that ... behalf of the assessee, the captioned appeals are dismissed as withdrawn. However, in the event, the assessee fails to avail the benefit of VSV Scheme for any bonafide reasons, then the assessee concerned shall be at liberty to seek restoration of original appeals for hearing before ITAT in accordance with

Zydus Hospira Oncology Private Limited, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

ITA 949/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Prathvi Raj Meena, CIT. D.RFor Respondent: Shri Prathvi Raj Meena, CIT. D.R
Section 10ASection 10BSection 143(3)Section 263

case of PCIT v. Mrs. Swatiben Biharilal Parekh (156 taxmann.com 267 (Gujarat), wherein the Hon'ble Court was pleased to hold that "Opting VSV Scheme and finalizing thereof is nothing but closure of disputes in respect of tax arrears which cannot be subsequently reopened by issuing notice under section ... result of this resolution, the assessee submitted that no revision proceedings under Section 263 can be initiated. The assessee had applied under VSV Scheme and had received a certificate in Form-3 dated March 12, 2021, under the VSV Act, issued by the Hon'ble Principal Commissioner of Income

Zydus Hospira Oncology Private Limited, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

ITA 948/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Prathvi Raj Meena, CIT. D.RFor Respondent: Shri Prathvi Raj Meena, CIT. D.R
Section 10ASection 10BSection 143(3)Section 263

case of PCIT v. Mrs. Swatiben Biharilal Parekh (156 taxmann.com 267 (Gujarat), wherein the Hon'ble Court was pleased to hold that "Opting VSV Scheme and finalizing thereof is nothing but closure of disputes in respect of tax arrears which cannot be subsequently reopened by issuing notice under section ... result of this resolution, the assessee submitted that no revision proceedings under Section 263 can be initiated. The assessee had applied under VSV Scheme and had received a certificate in Form-3 dated March 12, 2021, under the VSV Act, issued by the Hon'ble Principal Commissioner of Income

Krayon Marketing Private Limited, Delhi vs. ACIT, Circle-14(2), Delhi

In the result, appeal of the assessee is dismissed as

ITA 890/DEL/2024[2011-12]Status: DisposedITAT Delhi21 Nov 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareek

For Appellant: Shri Sameer Malhotra, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 147Section 148Section 68

further stated that the assessee does not wish to pursue the present appeal due to the exercise of the option for availing of the VSV Scheme and, consequently, requested that the written application for withdrawal of the appeal be granted. 4. The Ld. Sr. DR for the Revenue stated that

Ajay Sharma, New Delhi vs. ITO, Ward- 68(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1531/DEL/2018[2014-15]Status: DisposedITAT Delhi18 Nov 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshajay Sharma, Vs. Ito, H. No. 164, Sector-A, Ward-68(1), Pocket-C, Vasant Kunj, New Delhi New Delhi (Appellant) (Respondent) Pan:Actps6995D

For Appellant: Shri Sunil Kumar Tyagi, CAFor Respondent: Shri Poojan Rana, Sr. DR
Section 143(3)Section 4Section 91(1)Section 91(4)

wherein the Hon‟ble High Court after considering the intention of the assessee to avail the benefit of „Vivad se Vishwas Scheme-2020‟ (VSV scheme), had dismissed the appeal by observing in Para 7 to 9 as under:- “7. As observed, the assessee is given liberty to restore this appeal

Bhikhalal Chimanlal Shah, Ahmedabad vs. The ACIT, Circle-1(2), Ahmedabad

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

ITA 1354/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad23 Oct 2024AY 2012-13

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)

order Filed on CIT(A), CIT(A), (date) and Appeal No. Ahmedabad- Ahmedabad- 1/10367/2018-19 1/10162/2019-20 Acknowledgement Number 407203561100119 19105891105019 of Form 35 Settled under VSV Scheme No Yes CIT(A) disposed off the 15.07.2022 09.06.2022 appeal as settled in VSV Scheme 2.1. The assessee has chosen to avail Vivad

Rajeev Brijbhushan Bhatnagar, Mumbai vs. Income Tax Officer-28(2)(1), Mumbai, Vashi

In the result, the appeal of the assessee is allowed

ITA 4501/MUM/2024[2010-11]Status: DisposedITAT Mumbai22 Oct 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2010-11 Rajeev Brijbhushan Bhatnagar, Ito-28(2)(1), C/O Ca Himanshu Gandhi Tower No. 6, Vashi Railway Station Vs. Chartered Accountants 16Th Floor, Commercial Complex, Vashi, D Wing, Trade World Tower, Navi Mumbai-400703. Kamala Mills Compound, Lower Parel, Mumbai-400013. Pan No. Acfpb 2967 G Appellant Respondent

For Respondent: Mr. Himanshu Gandhi/
Section 147Section 148Section 154Section 250Section 271FSection 54

while passing the order in appeal filed against the penalty in appeal filed against the penalty order under section 271F which is settled under VSV Scheme 2020. order under section 271F which is settled under VSV Scheme 2020. order under section 271F which is settled under VSV Scheme 2020. Hence ... reproduced as under: CIT(A) is reproduced as under: “2. Decision It is seen that the appellant had opted for VsV scheme for penalty levied It is seen that the appellant had opted for VsV scheme for penalty levied It is seen that the appellant had opted for VsV scheme

DCIT, New Delhi vs. M/S Lvmh Watch & Jewelery India Pvt. Ltd., New Delhi

In the result, the appeals of the assessee as well as the revenue are dismissed

ITA 2748/DEL/2011[2004-05]Status: DisposedITAT Delhi21 Oct 2024AY 2004-05

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N M/S. Lvmh Watch & Vs. Dcit, Jewellery India Pvt. Ltd, Circle-4(1), International Trade New Delhi Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Acit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Assessee By : Shri Tapas Ram Mishra, Adv Shri Neeraj Kumar Sharma, Ar Shri Sahil Malhotra, Ar Revenue By: Shri Rajesh Kumar, Cit Dr Shri Gaurav Bansal, Sr. Dr Shri Kanv Bali, Sr. Dr Date Of Hearing 23/08/2024 Date Of Pronouncement 21/10/2024

For Appellant: Shri Tapas Ram Mishra, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 4Section 91(1)Section 91(4)

wherein the Hon‟ble High Court after considering the intention of the assessee to avail the benefit of „Vivad se Vishwas Scheme-2020‟ (VSV scheme), had dismissed the appeal by observing in Para 7 to 9 as under:- “7. As observed, the assessee is given liberty to restore this appeal

Lvmh Watch & Jewellery Indi (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee as well as the revenue are dismissed

ITA 4022/DEL/2010[2003-04]Status: DisposedITAT Delhi21 Oct 2024AY 2003-04

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N M/S. Lvmh Watch & Vs. Dcit, Jewellery India Pvt. Ltd, Circle-4(1), International Trade New Delhi Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Acit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Assessee By : Shri Tapas Ram Mishra, Adv Shri Neeraj Kumar Sharma, Ar Shri Sahil Malhotra, Ar Revenue By: Shri Rajesh Kumar, Cit Dr Shri Gaurav Bansal, Sr. Dr Shri Kanv Bali, Sr. Dr Date Of Hearing 23/08/2024 Date Of Pronouncement 21/10/2024

For Appellant: Shri Tapas Ram Mishra, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 4Section 91(1)Section 91(4)

wherein the Hon‟ble High Court after considering the intention of the assessee to avail the benefit of „Vivad se Vishwas Scheme-2020‟ (VSV scheme), had dismissed the appeal by observing in Para 7 to 9 as under:- “7. As observed, the assessee is given liberty to restore this appeal

ACIT, New Delhi vs. M/S. Lvmh Watch & Jewellery India Pvt. Ltd., New Delhi

In the result, the appeals of the assessee as well as the revenue are dismissed

ITA 3643/DEL/2010[2003-04]Status: DisposedITAT Delhi21 Oct 2024AY 2003-04

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N M/S. Lvmh Watch & Vs. Dcit, Jewellery India Pvt. Ltd, Circle-4(1), International Trade New Delhi Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Acit, Vs. M/S. Lvmh Watch & Circle-4(1), Jewellery India Pvt. Ltd, New Delhi International Trade Tower, 301-302, 3Rd Floor, Block-F, Nehru Place, New Delhi (Appellant) (Respondent) Pan:Aaacl7814N Assessee By : Shri Tapas Ram Mishra, Adv Shri Neeraj Kumar Sharma, Ar Shri Sahil Malhotra, Ar Revenue By: Shri Rajesh Kumar, Cit Dr Shri Gaurav Bansal, Sr. Dr Shri Kanv Bali, Sr. Dr Date Of Hearing 23/08/2024 Date Of Pronouncement 21/10/2024

For Appellant: Shri Tapas Ram Mishra, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 4Section 91(1)Section 91(4)

wherein the Hon‟ble High Court after considering the intention of the assessee to avail the benefit of „Vivad se Vishwas Scheme-2020‟ (VSV scheme), had dismissed the appeal by observing in Para 7 to 9 as under:- “7. As observed, the assessee is given liberty to restore this appeal

M/S Ufv India Global Education (Society), Chandigarh vs. DCIT, Exemption Circle-1, Chandigarh

In the result, appeal is allowed

ITA 516/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh20 Sept 2024AY 2018-19

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 516/Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 M/S Ufv India Global Vs. The Dcit Exemption, Circle-1, Education, बनाम Chandigarh Ggd Sanatan Dharma College, Ector 32-C, Chandigarh (U.T.) "थायी लेखा सं./Pan No: Aabcu7691M अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 13.08.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 20.09.2024

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 11Section 12ASection 2(15)Section 270ASection 270A(9)Section 8

Assessment order passed u/s 143(3) of the 27.12.2019 Act for the AY 2017-18 Filing of Form 1 & 2 under the VSV Scheme 18.05.2020 for the AY 2016-17 and AY 2017-18 Revision of Income Tax Return for the AY 30.09.2020 2019-20 Voluntary surrender of the exemption

Sikkim Distilleries Limited, East Sikkim vs. D.C.I.T. (TDS), Circle - 5, Gangtok

In the result, all the 12 appeals filed by the assessee are partly allowed for statistical purposes

ITA 1055/KOL/2024[2017-2018]Status: DisposedITAT Kolkata26 Aug 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 144Section 147Section 201Section 201(1)Section 206CSection 206C(7)

correct and the appeals are dismissed correctly, and no further action is required to be taken. 5. That subsequently, it was realised that the VsV Scheme had been opted for by the Company only with respect to orders passed u/s 147 r.w.s ... appeals against orders passed under sections 201(1) r.w.s. 2O1(1A) and 206C(6A) r.w.s. 206C(7) of the Act were also settled under VsV Scheme. 6. That post such realisation, the Company appointed a new counsel who confirmed that the orders of CIT(A) were passed on a mistaken

Sikkim Distilleries Limited, East Sikkim vs. D.C.I.T.(TDS), Circle - 5, Gangtok

In the result, all the 12 appeals filed by the assessee are partly allowed for statistical purposes

ITA 1054/KOL/2024[2017-2018]Status: DisposedITAT Kolkata26 Aug 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 144Section 147Section 201Section 201(1)Section 206CSection 206C(7)

correct and the appeals are dismissed correctly, and no further action is required to be taken. 5. That subsequently, it was realised that the VsV Scheme had been opted for by the Company only with respect to orders passed u/s 147 r.w.s ... appeals against orders passed under sections 201(1) r.w.s. 2O1(1A) and 206C(6A) r.w.s. 206C(7) of the Act were also settled under VsV Scheme. 6. That post such realisation, the Company appointed a new counsel who confirmed that the orders of CIT(A) were passed on a mistaken

Sikkim Distilleries Limited, East Sikkam vs. D.C.I.T. (TDS), Circle - 5, Gangtok

In the result, all the 12 appeals filed by the assessee are partly allowed for statistical purposes

ITA 1053/KOL/2024[2016-2017]Status: DisposedITAT Kolkata26 Aug 2024AY 2016-2017

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 144Section 147Section 201Section 201(1)Section 206CSection 206C(7)

correct and the appeals are dismissed correctly, and no further action is required to be taken. 5. That subsequently, it was realised that the VsV Scheme had been opted for by the Company only with respect to orders passed u/s 147 r.w.s ... appeals against orders passed under sections 201(1) r.w.s. 2O1(1A) and 206C(6A) r.w.s. 206C(7) of the Act were also settled under VsV Scheme. 6. That post such realisation, the Company appointed a new counsel who confirmed that the orders of CIT(A) were passed on a mistaken

Sikkim Distilleries Limited, East Sikkim vs. D.C.I.T.(TDS), Circle - 5, Gangtok

In the result, all the 12 appeals filed by the assessee are partly allowed for statistical purposes

ITA 1052/KOL/2024[2016-2017]Status: DisposedITAT Kolkata26 Aug 2024AY 2016-2017

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 144Section 147Section 201Section 201(1)Section 206CSection 206C(7)

correct and the appeals are dismissed correctly, and no further action is required to be taken. 5. That subsequently, it was realised that the VsV Scheme had been opted for by the Company only with respect to orders passed u/s 147 r.w.s ... appeals against orders passed under sections 201(1) r.w.s. 2O1(1A) and 206C(6A) r.w.s. 206C(7) of the Act were also settled under VsV Scheme. 6. That post such realisation, the Company appointed a new counsel who confirmed that the orders of CIT(A) were passed on a mistaken