Vivad Se Vishwas settlement coverage led related quantum and penalty appeals to be treated as withdrawn and dismissed.

Form No. 3 under the Direct Tax Vivad Se Vishwas Act, 2020 having already been issued in the quantum proceedings, the related penalty appeals arising from the same dispute were treated as covered by the settlement process. On that basis, the pending quantum and penalty matters were not examined on merits and were treated as withdrawn and dismissed.

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Issues: Whether the cross quantum and penalty appeals were liable to be treated as withdrawn and dismissed in view of the issuance of Form No. 3 under the Direct Tax Vivad Se Vishwas Act, 2020.

Analysis: Form No. 3 had already been issued in the quantum proceedings, and the penalty appeals arose out of the same underlying dispute. In these circumstances, the pending quantum and penalty appeals were treated as covered by the settlement process and not proceeded with on merits.

Conclusion: The appeals were treated as withdrawn and dismissed.

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