Vivad Se Vishwas settlement bars later revision under section 263 once the dispute is conclusively closed.

Once a tax dispute is conclusively settled under the Direct Tax Vivad Se Vishwas Act, 2020, the settlement attains statutory finality and matters covered by it cannot be reopened in other proceedings. Section 5(3) makes the order determining the amount payable conclusive, while Sections 6 and 8 bar re-agitation of the settled dispute under the Income-tax Act, 1961. Applying that finality, the Tribunal treated later assumption of revision jurisdiction under section 263 as impermissible and unsustainable after settlement.

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Issues: Whether revision jurisdiction under section 263 of the Income-tax Act, 1961 could be exercised after the assessee had settled the dispute under the Direct Tax Vivad Se Vishwas Act, 2020.

Analysis: The settlement under the Direct Tax Vivad Se Vishwas Act, 2020 was treated as a conclusive closure of the tax dispute. Section 5(3) makes the order determining the amount payable conclusive and bars reopening of matters covered by it in any other proceeding. Sections 6 and 8 reinforce that, once the statutory settlement is completed, the matter cannot be re-agitated through proceedings under the Income-tax Act. In view of this statutory finality and the binding jurisdictional view applied by the Tribunal, the later exercise of revision under section 263 was held to be impermissible.

Conclusion: The assumption of revision jurisdiction under section 263 after settlement under the Direct Tax Vivad Se Vishwas Act, 2020 was held to be invalid and unsustainable.

Ratio Decidendi: Once a tax dispute is conclusively settled under the Direct Tax Vivad Se Vishwas Act, 2020, matters covered by the settlement cannot be reopened or subjected to revision under the Income-tax Act, 1961.

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