Vivad se Vishwas eligibility: appeals set aside to CIT(A)/DRP and pending on the cutoff remain eligible for settlement. Matters set aside to the CIT(A)/DRP and remaining pending as of the statutory cutoff are deemed pending at that level and are eligible for settlement under Vivad se Vishwas; all issues either pending in appeal (including set aside issues) or for which the time to file appeal had not expired by the cutoff must be settled.