The appeal was filed with a delay of 958 days and the delay was condoned assigning certain reasons and as a consequence of the order passed by the court condoning the delay it was deemed that the appeal was filed within the period of limitation. Had the appeal been filed by the Department before the time stipulated under the Direct Tax Vivad Se Vishwas Scheme, 2020 the assessee could have very well availed of the benefit of the Scheme for the assessment year 2014-15. The assessee was directed to file the requisite application under the Scheme and such application should be deemed to have been presented well before the last date on which the benefit of the Scheme had come to an end the application should be processed and the requisite forms be issued to enable the assessee to pay the disputed tax in terms of the conditions contained under the scheme. The questions of law raised in the appeal under section 260A by the Department were left open (AY.2014-15).