All India Federation of Tax Practitioners
(Direct Tax Representation Committee)
(An Association of Advocates, Chartered Accountants & Tax Practitioners of India)

Ref. No. ………………

Date: 18.03.2020

Hon’ble Smt. Nirmala Sitharaman
Union Finance Minister
Government of India
Ministry of Finance,
North Block, New Delhi- 110001

Respected Madam,

Sub: The Direct Tax Vivad se Vishwas Act, 2020 – Request for three months extension without any extra charge of disputed tax

As you may be aware, the All India Federation of Tax Practitioners (the Federation in short) is one of the largest professional bodies of tax practitioners, advocates and chartered accountants – both of direct and indirect taxes. It was set up 43 years ago in 1976 and has a membership of over 9000 individuals and about 135 Tax Bar Associations in 27 States of India. Among other activities, it holds National Tax Conferences at different places in the country every 2-3 months and also publishes monthly newsletters and two monthly Journals one each on direct taxes and the GST. It has its head office at Mumbai and zonal offices at five different places as given in the left hand margin of this letter.

2. The Direct Tax Vivad se Vishwas Act, 2020, giving legal form to the Direct Tax Vivad se Vishwas Scheme, 2020, has been made law only on 17th March, 2020 after its approval by the Parliament of India and notification in the Government of India Gazette. The rules and forms will be used for implementing the Scheme are still to be formed and laid on the table of both the houses of the Parliament. There will thus hardly be any time left for the concerned taxpayers to avail of the benefits of this Scheme before 3151 March, 2020.

3. Apart from a few days left before 31st March, 2020, several Implementation Issues were raised In writing and sent to the Central Board of Direct Taxes (CBDT). Besides, many other Issues were raised during the course of discussions, at several places throughout the country, of the tax representatives, with Your Honour, the Chairman – CBDT and other senior officers. The clarifications on these important issues have still to be Issued by way of a supplementary list of FAQs.

4. The Novel COVID 19 virus and its spread has badly affected the morale and inclination of the taxpayers to avail of the benefits of the Scheme. The worldwide economic depression has further reduced their capacity to pay.

5. The Federation shall, therefore, be grateful if three months extension, till 30th June, 2020, is allowed without charging any extra amount of the disputed tax, interest or penalty. The Federation shall also be grateful if a suitable notification u/s 11 of the Direct Tax Vivad se Vishwas Act, 2020 is issued to extend the time for compliance by three months till 30th June, 2020, without charging any extra payment on the disputed tax, interest or penalty.

6. The Federation wishes to assure you that we and our affiliated Associations are making all possible efforts to encourage the affected taxpayers to avail of the benefits of this unique Scheme of the Government so as to end the tax litigation in the largest number of cases.

7. An early action r:s requested.

Thanking you,

Yours faithfully,

S. R. Wadhwa, IRS (Retd)
Advocate

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