CIT cannot exclude genuine disputes under VSV Act on Hyper-Technical grounds

Kapri International Pvt. Ltd. Vs Commissioner Of Income Tax (Delhi High Court) HC held that Reliance by the CIT on FAQ-13 is not tenable since as rightly argued by the learned counsel for the petitioner FAQ-13 relates to a pending waiver application before the department and not a proceeding emanating out of a decision by the department on a waiver application, which Co. Appl. 577/2019 was. This is also obvious since if the department itself is seized of a demand by the assessee and has not passed a decision on it, then there is no „dispute‟ as yet which has fructified. It may be noted tha...