The appellant has settled the dispute under Vivad se Vishwas in an assessment year. Whether it is open for Revenue to take a stand that the additions have been accepted by the appellant and hence he cannot dispute it in future assessment years?

Vivad se Vishwas settlement does not constitute acquiescence, preventing revenue from treating settled additions as accepted later.

A Vivad se Vishwas settlement does not constitute a concession of the disputed tax position; the Explanation to Clause 5 provides that a declaration under the scheme shall not be treated as acquiescence by the declarant or the income-tax authority, and neither party may contend in appeals or petitions that the disputed issue was accepted by reason of the settlement.