For AY 2009-10, additions were made including disallowance of freight charges. CIT(A) partly allowed relief based on DTAA; ITAT confirmed in assessee’s favour. Revenue filed appeal before High Court. Meanwhile, assessee opted under DTVSV Act, 2020. PCIT issued Form-3 demanding full disputed tax instead of 50%. On writ the Court  held that under S. 2(j) and s. 3(1) proviso, only 50% of disputed tax is payable when appeal is in Revenue’s favour. Higher demand by the Department was contrary to the scheme and therefore illegal. Fresh Form-3 was directed to be issued.(AY. 2009-10)