Last date for payment of tax with extra amount is not yet notified . The assessee can  make payment ,  however the assessee has to pay extra amount  . Please refer CBDT Circular No 9 dt 22-4 -2020 (2020) 422 ITR 131 (St.),   Q . No. 28 and answer given by the CBDT , it will be 110 % of the disputed tax

Scheme is  not available . NOTIFICATION S.O. 964(E) [NO. 09/2021/F.NO. IT(A)/01/2020-TPL], DATED 26-2-2021 the scheme was extended up tp 31 st March , 2021  ( 2021) 432 ITR 13 (St)    .  However  for the  payment of tax  at concessional rate the period was extended up to 30 th June 2021   

The assseee may   write to the CBDT  and also may  file writ before High Court .

Assessee  may write  to the   Designated Authority for rectification .  If there is any  mistake in calculation   the  Designated Authority may  rectify the same ,  before issue of final certificate u/s 5 (1) of Vivad Se Vishwas .  Assessee  may also write to the Chairman CBDT explaining the  difficulty,   they will be able to guide you . If  you don’t receive any reply from the Designated Authority , you  may have to file writ before High Court .

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Please refer CBDT Circular No .21 /2020 dt 4-12 -2020   Q. 59 . and  Ans . wherein the CBDT has clarified that , if the time limit for filing appeal during the period from 1 st April 2019 to 31 st Jan , 2020 ( both dates included in such period ) and the application   for condonation  is filed before the date of issue  of this Circular ( 4-12 -2020) and appeal is admitted by the  appellate authority before filing of the  declaration , such  appeal will be deemed to be pending as on 31 st Jan 2020 .  

In case the assessee has filed the application of Condonation of delay   and the appeal is condoned then only thee assessee can avail the benefit of the scheme . The assessee may  verify from the portal ,whether any order has been passed by the CIT ( A) . The assessee may also write to the CBDT  explaining the facts of the case and consider the application of the assessee. In case no reply is received within reasonable time , the assessee may have to file writ before High Court.

Please refer  CBDT Circular No 21/ 2020 .  dt  4-12 -2020 .  Q. No 89 and answer given by CBDT .

Q.89 . Once declaration is filed by assessee u/s 4 of Viivad Se Vishwas  can the same be revised ? If yes , at what stage of the proceedings will the same be allowed ?

Ans . Yes , declaration can be revised any number of times before DA issues a certificate under section 5 (1) of Vivad Se Vishwas .

 You may contact the  Designated Authority . If there is any clerical mistake in the form the  Designated Authority may accept the revised form , before issue of final certificate u/s 5 (1) of Vivad Se Vishwas .  You may also write to the Chairman CBDT explaining the  difficulty,   they will be able to guide you . If  you don’t receive any reply from the Designated Authority , you  may have to file writ before High Court .

The view expressed by the professional is  correct view .

We presume that the notice is issued in respect of search initiated  u/s 132 or books of account  , other documents or any assets requisitioned  under section  132A on or before Ist April n, 2021 . The notice can be issued for six assessment years immediately preceding the assessment year relevant to the previous year in which search is concluded or requisition is made and for the relevant assessment year or years referred in section  153A (1) of the Act . The assessee should file the returns under  protest . After the returns are filed , the assessee should make an application for  furnishing the  copy of prior approval  , satisfaction recorded etc.        

Designated Authority has the power to rectify , you may make an application . Please refer CBDT Circular No .21/2020 dt.4 -12-2020 ,  Q. 89 and answer given by CBDT . Ans. Yes , declaration can be revised any number of times before DA issues a certificate under section 5(1)) of  Vivad se Vishwas.  In case the Designated Authority refusing to rectify the mistake apparent,   the assessee   may file writ before High Court .

The assessee may have to file writ before the High Court . One has to verify whether the assessee has filed an application for condonation of delay along with the appeal . Please Refer Circular No 21 dt 4 -12 -2-2020 , Q. No 59 and answer Given by the CBDT  on the issue of time limit  for filing of an  appeal . Ans: If the time limit for filing appeal expired during the period from 1 st April , 2019 to 31 st Jan 2020 ( both dates included in the period ) and the application for condonation is filed before the date of issue of this circular , and the appeal is admitted  by the appellate authority before due date of filing of the declaration , such appeal will be deemed to be pending as on 31 st Jan 2020 .  

On similar issue  writ has been filed before Delhi High Court and Bombay High Court  the  final orders are awaited . It may be desirable to file the writ , otherwise the  assessee  may not get  the refund of the amount paid under the scheme .

The Appellant  will get the form No 5 in due course of time .  As regards pendency of appeal before  CIT (A) is concerned it  will be treated as deemed to be withdrawn . Please refer Circular No  9  dt 22-4 2020 ,   Q. no 43 and answer given by CBDT   Ans.: Under the amended procedure no appeal is required to be withdrawn before  grant of certificate by DA. After grant of certificate by DA under section  5  the appellant is required to with draw the appeal ----.    On receipt of Form No 5 the  Appellant may inform the  Office of the CIT (A) to pass a consequential order in view of the Form No 5 received under the Scheme . In the mean time the Appellant  can make an request to Designated Authority to issue the form No 5 at the earliest .