Pending the application u/s 264 of the Act, the Petitioner preferred to settle the litigation under DTVSV Act, 2020. On filing the declaration u/s 4(1) of DTVSV Act, 2020, the Petitioner was asked to justify his claim that there is a ‘disputed tax’ when there is no ‘disputed income’ as per the relief sought in the applications filed u/s 264 of the Act. The Petitioner responded to the same and submitted that as per section 2 (1)(a)(v), an assessee whose application is pending on the specified date is an ‘appellant’ for the purpose of DTVSV Act, 2020. The disputed tax in such cases is defined in section 2(1)(j)(F) as the amount of tax payable by the appellant, if such application for revision was not accepted. In the Petitioner’s case there are ‘tax arrears’ as per the definition in section 2(1)(o) of the DTVSV Act, 2020. Thus, the Petitioner determined the amount payable u/s 3(a) of DTVSV Act, 2020. The Designated Authority did not appreciate the said explanation of the Petitioner and rejected the declaration without assigning any reason for the same . On writ the Court held that  The Designated Authority cannot reject the declaration filed under section 4(1) of the DTVSV Act, when the declarant’s case does not fall under section 4(6) and in any of the disqualifications mentioned in section 9 of the said Act . High Court directed the Designated Authority to act upon the declaration of the Petitioner in Form 1 as per law within a period of two weeks.    (WP No: 611 dt   09.04.2021) (AY. 1987-88 to 1998-99 )