Case Law Details
Reliance Infrastructure Ltd. Vs ACIT (ITAT Mumbai)
CBDT Circular no. 9/2020 dated 22/04/2020, question no. 19, clearly enables the assessee to avail Vivad Se Vishwas Scheme to avail VSV only for one proceeding , even when two parallel proceedings were pending before appellate forums.
Facts-
The assessee had availed Vivad Se Vishwas Scheme by filing an application in Form No.1 & 2 only in respect of first proceedings pending before the ld. CIT(A) i.e.143(3) r.w.s. 250 dated 08/05/2018. The only dispute pending in this proceeding was settled by the assessee under Vivad Se Vishwas Scheme for the A.Y.2014-15.
However, the second appeal which was pending before the ld. CIT(A) against the order passed by the ld. AO u/s.143(3) r.w.s. 147 of the Act dated 18/03/2019 was never sought to be settled by the assessee under Vivad Se Vishwas Scheme.
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