If appeal involving issue of disallowance under section 40(a) (i)/(ia) of the Act is settled under the Scheme, whether consequential relief will be available in proceedings under section 201 of the Act initiated qua the same payment/ deduction ?

Disallowance under section 40a(i)/(ia) bars consequential relief in section 201 proceedings after settlement under the Scheme.

Settlement under the Vivad Se Vishwas scheme of an appeal on disallowance under section 40(a)(i)/(ia) does not entitle the payer to consequential relief in subsequent section 201 proceedings initiated in respect of the same payment or deduction; the Scheme's resolution does not operate to modify separate TDS liability proceedings.