2024 (4) TMI 603

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....ndents Through: Mr Prashant Meharchandani, Sr Standing Counsel with Mr Akshat Singh, Standing Counsel. Mr Ravi Prakash, CGSC with Ms Usha Jamnal, Adv. for UOI. RAJIV SHAKDHER, J.: (ORAL) 1. This writ petition concerns Assessment Year (A.Y.) 2011-12. 2. Via the instant writ petition, the petitioner/assessee seeks to assail the order [Annexure P-22] passed by respondent no.1/revenue rejecting t....

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....[sic...application], as per CBDT circular No-7/2020 dated 04.03.2020 in FAQ No-7, 11,14 and 36 you are not eligible to avail the benefit of VsV scheme. In the present case applicant trying to settle the part of appeal filed by the Revenue without considering the Revenue's SLP before Apex Court." 5. The record discloses the petitioner/assessee filed its Return of Income (ROI) on 30.11.2011 de....

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....s of the petitioner/assessee while dismissing others. 6. Pursuant to the directions passed by the DRP, the AO framed a final assessment order dated 18.12.2015 computing the income of the petitioner/assessee at Rs. 2,28,02,36,684/-. The addition of interest from ECBs was retained, taking the total taxable income to Rs. 4,43,08,79,550/-. 7. Aggrieved by the final assessment order dated 18.12.2015,....

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....peal of the petitioner/assessee before the Delhi High Court was numbered ITA 806/2017 while the respondent's/revenue's appeal was numbered ITA 1072/2017. 10. The denial of relief to the petitioner/assessee under the provisions of the Direct Tax Vivas Se Vishwas Act, 2020 [in short, "VSV Act"] is pivoted on the fact that the petitioner/assessee has chosen to settle only one of the three (3) matter....