Dismissing the petition the Court held that  the facts were that the assessee was aware about the order dated May 7, 2019 passed by the Full Bench of the Tribunal and the order dated June 4, 2019 passed by the Division Bench of the Tribunal. In such circumstances, merely because the assessee received certified copy of the order from the Tribunal on December 22, 2020, it could not contend that the appeal was pending before the Tribunal on the date of filing of the application in forms 1 and 2 under the provisions of the Direct Tax Vivad se Vishwas Act, 2020. The rejection of the declaration under the 2020 Act was justified.