https://www.taxtmi.com/caselaws?id=418692 The Direct Tax Vivad se Vishwas Act, 2020 is to be read as a beneficial settlement scheme for resolving pending direct tax disputes, and declarations should not be rejected on a rigid reading of a CBDT circular on delayed appeals. Where an appeal is accompanied by a pending condonation application and delay is later condoned, the appeal relates back to the date it should have been filed and is treated as pending for the scheme. The circular's cutoff for condonation was held to be clarificatory, not an inflexible bar, because an artificial distinction between similarly placed declarants would be inconsistent with the object of dispute resolution and Article 14. The settlement window remained time-bound, but the declarations could not be denied on that cutoff alone. en-us Thu, 17 Feb 2022 00:00:00 +0530 Sat, 30 Apr 2022 16:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418692 The Direct Tax Vivad se Vishwas Act, 2020 is to be read as a beneficial settlement scheme for resolving pending direct tax disputes, and declarations should not be rejected on a rigid reading of a CBDT circular on delayed appeals. Where an appeal is accompanied by a pending condonation application and delay is later condoned, the appeal relates back to the date it should have been filed and is treated as pending for the scheme. The circular's cutoff for condonation was held to be clarificatory, not an inflexible bar, because an artificial distinction between similarly placed declarants would be inconsistent with the object of dispute resolution and Article 14. The settlement window remained time-bound, but the declarations could not be denied on that cutoff alone. Case-Laws Income Tax Thu, 17 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418692