Srinivasan Jayaprakasam v. CBDT (2025) 171 taxmann.com 101 /473 ITR 245 (Mad)(HC)

Direct Tax Vivad Se Vishwas Scheme, 2024 (2024) 467 ITR 1 (St)(63)

S. 89:Definitions-Appellant-Benefit of Vivad Se Vishwas Scheme, 2024 extended to those assesses in whose case the time for filing appeal has not expired as on 22 July 2024.[S.89(1)(a)) DTVSV Act, 2020, S. 2(1)(a), Art. 226]

The assessee had filed a writ challenging the constitutional validity of the Vivad Se Vishwas Scheme, 2024, inasmuch as it has confined the meaning of an ‘Appellant’ to a person in whose case an appeal or a writ petition or a special leave petition has been filed as on 22 July 2024. The Hon’ble Madras High Court vide its interim order 19 December 2024 had directed the Central Board of Direct Taxes (‘CBDT’) to consider extending the benefit of the Vivad Se Vishwas Scheme, 2024 to those assesses in whose case the time for filing appeal has not expired as on 22 July 2024 which was duly accepted by CBDT vide its circular dated 20 January 2025. Accordingly, the writ stands disposed.

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