The Principal Commissioner rejected that assessee’s declaration under the Direct Tax Vivad se Viswas Act, 2020 on the ground that the miscellaneous application filed by the assessee under section 254(2) of the Income-tax Act, 1961 was not covered under the 2020 Act since it was not filed in pursuance of an appeal “dismissed in limine”. On a writ petition: allowing the petition, that “Frequently Asked Question No. 61”, of the Circular No. 21 of 2020 dated December 4, 2020 ((2020) 429 ITR (St) 1) issued by the Cental Board of Direct Taxes to the extent that it restricts the benefit to appeals “dismissed in limine” was not only adverse to the interests of the assessee but also contrary to the objects and reasons of the 2020 Act and therefore, was liable to be struck down. The rejection order passed by the Principal Commissioner was quashed and set aside. The Principal Commissioner was directed to issue acknowledgment in form 3 against the application made by the assessee in forms 1 and 2 under the 2020 Act.