In a case ITAT has passed order giving relief on two issues and confirming three issues. Time to file appeal has not expired as on specified date. The taxpayer wishes to file declaration for the three issues which have gone against him. What about the other two issues as the taxpayer is not sure if the department will file appeal or not?

Deemed appeal settlement under Vivad se Vishwas lets an assessee selectively settle appeals; department may still appeal other issues.

Vivad se Vishwas treats filings made before expiry of appeal periods as a deemed appeal and allows separate, issue wise declarations by the assessee, the department, or both; an assessee may settle only his deemed appeal while the department may still pursue appeals on other issues under the extant appellate procedure.