2023 (12) TMI 1493 - HC - Income Tax

Settlement under Direct Tax Vivad Se Vishwas Act enables closure of pending revenue proceedings upon issuance of settlement certificates.

Settlement under the Direct Tax Vivad Se Vishwas Act, 2020 and issuance of requisite settlement certificates operate as a statutory mechanism to ... Disputes settled under the provisions of the Direct Tax Vivad Se Vishwas Act, 2020 - requisite certificates have been issued - discrepancies in the Permanent Account Numbers (PANs) - HELD THAT:- It appears, that the issue has been resolved as per the instructions received by Mr Chandra via an email dated 05.12.2023; a hard copy of which has been placed before us. Accordingly, the prayers made in the above-captioned applications are allowed. Issues: Whether, in view of settlement of disputes under the Direct Tax Vivad Se Vishwas Act, 2020 and issuance of requisite certificates, the appellant/revenue's pending appeals should be closed.Analysis: The Court records that the disputes between the parties have been settled under the Direct Tax Vivad Se Vishwas Act, 2020 and that requisite settlement certificates have been issued. The Revenue, through its counsel, has returned with instructions to allow the prayers in the connected applications and to close the Revenue's appeals. A previously noted administrative discrepancy regarding Permanent Account Numbers has been resolved by an email dated 05.12.2023, a copy of which has been placed on record. On these facts, and having regard to the effect of a statutory settlement scheme resulting in issuance of certificates, the Court permits the procedural step of closing the appeals to give effect to the settlement.Conclusion: The Court allows the prayers in the listed applications and directs that the appellant/revenue's appeals stand closed.