The petitioner challenged the assessment order by filing an appeal before the Tribunal  , which was disposed by the Tribunal deciding various issues. The petitioner challenge  the order before High Court . High Court admitted some of the issues  and remanded  the matter in some of the issues . After giving effect the petitioner challenged the  matter before Tribunal . Supreme court issued  notice in the SLP filed by the Revenue . On March 17 , 2020 the Direct Tax Vovad Se Viswas Act was passed by Parliament  ( 2020)  422 ITR 121( St). The petitioner filed an application under Direct Tax Vivad Se  Vishwas Act to settle the deemed appeal of the Department against the order of the Tribunal dated 16-9-2019. The application  was  rejected on the ground that the assessee has not settled the SLP pending  in the Supreme Court . Revenue relied on the questions and answers of the CBDT  circular No 99 of 2020 dated Aprl 22, 2020 ( 2020) 422 ITR 131 ( St. , (134)  On writ allowing the petition the Court held that   the issue raised by the Department in the special leave petition filed before the Supreme Court was in respect of deduction for salary paid to expatriates and the applicability of section 115JB of the Income-tax Act, 1961. However, this issue was not at all connected with the appeal arising from the order of the Tribunal dated September 16, 2019 wherein the issues of taxability of interest on external commercial borrowings and levy of interest under section 234D of the 1961 Act were involved. Since, the issues involved in the two appeals were different and unconnected the contention of the Department that the assessee ought to have settled the special leave petition pending in the Supreme Court, along with the appeal of the Department was incorrect and bad in law. (AY. 2007-08)