Sabka Vishwas settlement makes pending appeals cease after discharge certificate, with departmental appeal deemed withdrawn and assessee appeal withdrawn.

Settlement under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 becomes conclusive once a discharge certificate is issued, and no further proceedings continue on the settled dispute. Where both the assessee's appeal and the Department's appeal were covered by the scheme and the designated committee determined the tax dues, the pending appeals did not survive for adjudication. The Department's appeal stood dismissed as deemed withdrawn, and the assessee's appeal stood withdrawn in consequence of the statutory settlement mechanism.

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Issues: Whether, after settlement of the dispute under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 and issuance of a discharge certificate, the assessee's appeal and the Department's appeal survived for adjudication or stood withdrawn/deemed withdrawn.

Analysis: The dispute had been declared under the Scheme in respect of both the assessee's appeal and the Department's appeal, and the designated committee issued a discharge certificate after determining the payable amount. The statutory scheme provides for determination of tax dues where appeals are pending on both sides and also contemplates revision of the declared amount by the designated committee where necessary. Once the discharge certificate is issued, the settlement attains conclusiveness and no further proceedings are to continue. The circular issued by the Board also clarifies that deemed withdrawal applies to departmental appeals as well.

Conclusion: The Department's appeal stood dismissed as deemed withdrawn and the assessee's appeal stood withdrawn on account of the settlement under the Scheme.

Final Conclusion: The dispute was brought to an end by the statutory settlement mechanism, and both pending appeals ceased to survive for further adjudication.

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