Prosecution for delayed self-assessment tax payment remained separate from Vivad Se Vishwas relief, so interference was refused.

Criminal prosecution for delayed payment of self-assessment tax was treated as distinct from the assessment additions covered by an application under the Direct Tax Vivad Se Vishwas Act, 2020. The Court held that acceptance of the application would not automatically affect a prosecution founded on late payment of self-assessment tax, because the prosecution arose from a separate issue and was not shown to fall within the Act's objective or purpose. No interference with the impugned judgment was warranted, and the challenge failed.

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Issues: Whether criminal prosecution for delayed payment of self-assessment tax could be interfered with on the ground that an application under the Direct Tax Vivad Se Vishwas Act, 2020 related only to additions made in the assessment order.

Analysis: The prosecution arose from a separate and different issue from the assessment additions covered by the application under the Act. Acceptance of the application would not have automatically affected the prosecution, which was based on delayed payment of self-assessment tax. The dismissal of the prosecution case was not treated as material to the objective and purpose of the Act.

Conclusion: No interference was called for with the impugned judgment, and the challenge failed.

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