In case where disputed tax contains qualilYing tax arrears as also non-qualifying tax arrears (such as, tax arrears relating 10 assessment made in respect of undisclosedforeign income): (i) Whether assessee is eligible to the Vivad se Vishwas itself? (ii) If eligible, whether quantification of disputed tax can exclude/ignore non-qualifying tax arrears?

Cases with Non-Qualifying Issues Like Undisclosed Foreign Income Ineligible for Vivad se Vishwas Scheme Settlement.

If tax arrears include non-qualifying issues, such as undisclosed foreign income, the case is ineligible for the Vivad se Vishwas scheme. The scheme does not allow for partial settlement of disputes for a given assessment year. All issues within a pending appeal must be resolved under the scheme, and if any issue disqualifies the case, no declaration can be filed.