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 extinguish the disputed tax claims, and on those operative facts the revenue has instructed withdrawal of its proceedings; the administrative discrepancy concerning Permanent Account Numbers was resolved on record. The combined legal effect is to permit procedural closure of the revenue's pending appeals and grant the reliefs sought in the connected applications so as to give effect to the statutory settlement scheme.

---

---

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.

---