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Court Clarifies 'Dispute' in Vivad Se Vishwas Scheme; Directs CIT to Reassess Petitioner's Settlement Claim.
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....Direct Tax Vivad Se Vishwas Scheme - definition of ‘dispute’ under the VSV Act / Rules - attempt by the CIT to exclude a genuine disputant of tax liability, like the petitioner, from the possibility of settlement under the VSV Act is extremely hyper-technical. The interest as demanded under Section 220 (2A) which is 1% for every month of the period of delay as opposed to an application of Rule 154 of the Companies Court Rules which provides for an interest ceiling at the rate of 4% interest for companies in liquidation, is a huge statutory benefit given to companies in liquidation. It cannot be contended that the respondent CIT is not qualified to account for the beneficial provisions for a company in liquidation. - PCIT / CIT directed to re-examine the declaration filed - HC....