Prosecution for Delayed Self-Assessment Tax Not Ground to Deny Vivad se Vishwas Relief

Macrotech Developers Limited Vs PCIT (Bombay High Court) The Bombay High Court examined the validity of Question No.73 of Circular No.21/2020-Income Tax dated 04.12.2020 issued under the Direct Tax Vivad se Vishwas Act, 2020 (“Vivad se Vishwas Act”). The petitioner, a public limited company engaged in real estate development, had filed its return for Assessment Year (AY) 2015-16 and paid self-assessment tax, though part of it was paid after the due date. The Income Tax Department issued a show cause notice proposing prosecution under Section 276-C(2) of the Income Tax Act, 1961 for alleged...