Review Petition Qualifies as Pending Proceedings under Direct Tax Vivad Se Vishwas Act, 2020; Revised Declaration Accepted.

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....Benefit under Direct Tax Vivad Se Vishwas Act, 2020 was considered for a case where no appeal, writ petition, or special leave petition was pending before the appellate forum as on the cut-off date, but a review petition against dismissal of the special leave petition was pending. The court held that even though the scope of a review petition is limited, it partakes the character of pending proceedings. The CBDT circulars clarified that pendency of arbitration proceedings and miscellaneous applications would meet the requirement u/s 2(1)(j) of the Act, even if no appeal was pending. The court ruled that the review petition would also be covered under the "Vivad Se Vishwas Scheme" as the DTVSV Act provides for deviation from strict applicati.........