The High Court upheld the rejection of the assessee’s declaration filed under the Direct Tax Vivad Se Vishwas Act, 2020. The assessee’s appeal before the Tribunal had not been admitted as the Tribunal rejected the application for condonation of delay. The High Court had also dismissed the assessee’s subsequent appeal against the Tribunal’s order, and no Special Leave Petition was filed in the Supreme Court. Consequently, the Court held that as no appeal was pending before any appellate forum on the date of filing the declaration, the assessee was not eligible for the benefits of the Act. The rejection of the declaration was, therefore, held to be valid. (AY. 2001-02)