Whether Vivad se Vishwas can be availed for proceedings pending before Authority of Advance Ruling (AAR)? If a writ is pending against order passed by AAR in a HC will that case be covered and how disputed tax to be calculated?

Vivad se Vishwas eligibility limited where AAR orders determine total income; disputes before AAR otherwise excluded.

Vivad se Vishwas is not available for disputes pending before the Authority for Advance Ruling, except where the AAR order has determined the total income and a writ against that order is pending in a high court; in such cases the taxpayer may apply, disputed tax is calculated per the AAR's determination and the Assessing Officer shall pass consequential orders. If the AAR has not determined total income, the dispute cannot be covered-for example, a finding of a Permanent Establishment without attributed income is not eligible.