Vivad se Vishwas settlement coverage rendered connected tax appeals infructuous after the disputed amounts were declared and tax was paid.

Declarations filed under the Direct Tax Vivad se Vishwas Scheme covered the disputed principal, pre-award interest and interest additions, and tax on the declared amounts had been paid. Because the revenue did not dispute that the contested interest amounts were included in the scheme declaration for Assessment Year 2019-20, no surviving controversy remained for adjudication. The connected revenue appeals for Assessment Years 2017-18, 2018-19 and 2019-20 were therefore infructuous, and the assessee's appeal for Assessment Year 2019-20 was treated as withdrawn.

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Issues: Whether the appeals survived in view of the declarations filed under the Direct Tax Vivad se Vishwas Scheme, 2024 and the tax already paid on the amounts covered by the disputed additions.

Analysis: The assessee's declarations under the scheme covered the principal amount, pre-award interest, and the interest additions that were in dispute across the assessment years. The relevant certificate had been issued for Assessment Year 2019-20, and the tax on the declared amounts had been paid. In respect of the remaining years, the declarations were not processed within the prescribed time, and the revenue did not controvert the factual position that the disputed interest amounts were already included in the scheme declaration for Assessment Year 2019-20. The appeals were therefore found to have no surviving controversy for adjudication.

Conclusion: The revenue appeals for Assessment Years 2017-18, 2018-19, and 2019-20 were held to be infructuous, and the assessee's appeal for Assessment Year 2019-20 was treated as withdrawn.

Final Conclusion: No substantive tax dispute remained for decision, as the disputed amounts stood covered by the settlement scheme and the pending appeals ceased to survive.

Ratio Decidendi: Where the disputed additions are covered by a valid declaration under a settlement scheme and the tax on the covered amounts has been paid, the connected appeals become infructuous or withdrawn and do not require adjudication on merits.

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