AO passed assessment order making addition to the total income pertaining to the estimation of profit 8% of transactions of shares carried out during the year under consideration by the assessee on NSE. The Pr. CIT found the whole transaction of shares as unexplained and ordered fresh assessment. The Tribunal set aside the fresh assessment holding that the Pr. CIT was not justified to initiate proceedings. The Tribunal observed that Section 6 of the Direct Tax Vivad Se Vishwas Act, 2020, makes it very clear that once there is a compliance with the timeliness specified under section (5), the designated authority shall not institute any proceedings in respect of an offence or aims or levy any penalty or charge any interest under the Income-tax in respect of the tax arrears. The Hon’ble Gujrat High Court upheld the order of the Tribunal and held that it was not open for the authorities to initiate proceedings under section 263 of the Act, when they were barred.(AY. 2012-13)