https://www.taxtmi.com/caselaws?id=429602 An appeal filed before the appellate forum remains "pending" for Vivad Se Vishwas Scheme eligibility even if it is delayed or awaiting condonation, because pendency begins with filing and does not require prior admission or validation of the appeal. The Court held that CBDT circulars and FAQs cannot narrow the statutory meaning of "pending" by imposing a precondition not found in the Act. A contrary circular is ineffective to the extent of the inconsistency, and the rejection of settlement based on delayed filing was unsustainable. The quantum and penalty disputes were therefore treated as eligible for settlement under the statute. en-us Fri, 28 Oct 2022 00:00:00 +0530 Tue, 01 Nov 2022 13:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429602 An appeal filed before the appellate forum remains "pending" for Vivad Se Vishwas Scheme eligibility even if it is delayed or awaiting condonation, because pendency begins with filing and does not require prior admission or validation of the appeal. The Court held that CBDT circulars and FAQs cannot narrow the statutory meaning of "pending" by imposing a precondition not found in the Act. A contrary circular is ineffective to the extent of the inconsistency, and the rejection of settlement based on delayed filing was unsustainable. The quantum and penalty disputes were therefore treated as eligible for settlement under the statute. Case-Laws Income Tax Fri, 28 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429602