2020 (10) TMI 1208

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....me Tax Appellate Tribunal, Chennai, 'D' Bench ('the Tribunal' for brevity) in I.T.A.No.1980/Mds/2010 for the Assessment Year 2004-05. The appeal has been filed, raising the following Substantial Questions of Law for consideration: "1.Whether on the facts and in the circumstances of the case, the Tribunal was justified in holding that Section 28(iv) of the Act applies and the imaginary value of shares is to be assessed as deemed profits in the hands of assessee-HUF? 2. Whether the Tribunal was correct in law in upholding the addition by the officer without establishing the nexus between the allotment of shares and the business of assessee for attracting the provisions of Section 28(iv) of the Act? 3....

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.... to file the application / declaration in Form No.I. 4. It may not be necessary for this Court to decide the Substantial Questions of Law framed for consideration on account of certain subsequent developments. The Government of India enacted the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) to provide for resolution of disputed tax and for matters connected therewith or incidental thereto. The Act of the Parliament received the assent of the President on 17th March 2020 and published in the Gazette of India on 17th March 2020. 5. In terms of the said Act, the assessee has been given an option to put an end to the tax disputes, which may be pending at different levels either before the First Appellate Authority or before the Tr....