On writ the High Court directed the Tribunal to decide the matter afresh. Meanwhile with the enactment of the Direct Tax Vivad Se Vishwas Act, 2020 on March 17, 2020 ([2020] 422 ITR (St.) 121), the assessee made declaration in form 1 along with an undertaking in form 2 according to the provisions of the 2020 Act. The assessee indicated an amount payable under the 2020 Act as Rs. 7,50,014 which was 50 per cent. of the disputed tax. On January 28, 2021, form 3 was issued by the designated authority indicating the amount payable as Rs. 15,00,029 which was 100 per cent. of the disputed tax. On a writ  the Court held that the whole process resurrected under the orders of the High Court was not the proceeding in the Tribunal by the assessee but of the Revenue preferred under section 253 of the Act where the Revenue was the appellant. May be the appeal by the Revenue is revived at the instance of the assessee because of its proceedings in the High Court, but that would by no stretch of imagination make the appeal before the Tribunal an appeal by the assessee under section 253 of the Act. Hence the first proviso to section 3 of the 2020 Act would become applicable and, accordingly, the amount payable by the assessee would be 50 per cent. of the amount, viz., 50 per cent. of the disputed tax.( AY. 2002-03)