Court directs filing Form I under Direct Tax Vivad Se Vishwas Act, grants liberty to restore appeal. Substantial Questions of Law left open.

The Court directed the appellant to file Form No.I before a specified date and instructed the competent authority to process the application promptly under the Direct Tax Vivad Se Vishwas Act, 2020. The appellant was granted liberty to restore the appeal if the decision on the declaration filed under Section 4 was unfavorable. The Tax Case Appeal was disposed of with liberty, leaving the Substantial Questions of Law open for future consideration, with no costs awarded.

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Issues:
1. Challenge to the order of the Income Tax Appellate Tribunal for the Assessment Year 2011-12.
2. Consideration of exemption in the sale of agricultural land and deduction under section 54F of the Income Tax Act.
3. Disallowance of cost of improvement in providing Modern Kitchen in the flats purchased.
4. Benefit of Vivad Se Vishwas Scheme for resolving tax disputes.
5. Interpretation and application of the Direct Tax Vivad Se Vishwas Act, 2020.

Analysis:
The appellant challenged the order of the Income Tax Appellate Tribunal for the Assessment Year 2011-12 under Section 260 A of the Income Tax Act, 1961. The Substantial Questions of Law raised included the consideration of exemption in the sale of agricultural land, deduction under section 54F of the Income Tax Act, and the disallowance of the cost of improvement in providing Modern Kitchen in the flats purchased. The appellant intended to avail the benefit of the Vivad Se Vishwas Scheme to resolve tax disputes and was taking steps to file the application in Form No.I.

The Court noted subsequent developments related to the enactment of the Direct Tax Vivad Se Vishwas Act, 2020, aimed at resolving disputed tax matters. The Act provided declarants with the option to settle tax disputes pending at different levels. The Act defined "disputed tax" and outlined the process for filing declarations and determining the amount payable by the declarant. Provisions under Sections 3, 4, 5, and 6 of the Act detailed the procedure for resolving tax disputes and granting immunity from penalties in certain cases.

The Court directed the appellant to file Form No.I before a specified date and instructed the competent authority to process the application in accordance with the Act promptly. The Court granted the appellant liberty to restore the appeal if the decision on the declaration filed under Section 4 was not favorable. The Tax Case Appeal was disposed of with the mentioned liberty, leaving the Substantial Questions of Law open for future consideration. No costs were awarded in this judgment.

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