Srishtii Infra Housing Pvt. Ltd. v. PCIT (2023) 330 CTR 167(Delhi)( HC) IA Housing Solution Pvt Ltd v. PCIT (2023) 330 CTR 167(Delhi)( HC)

Direct Tax Vivad Se Vishwas Scheme, 2020

S.3: Amount payable by the declarant – Time and manner of payment -Failure to pay the amount of disputed tax before the last date- Declarations ought to be accepted and payment to be made with simple interest @9% within four weeks.[ S. 5 , Art , 226 ]

The assessee having filed declarations under the Direct Tax Vivaad Se Vishwas Act, 2020, even if it failed to make payment before the last date stipulated for paying the disputed tax due to the death of one of the directors of the company, it ought to be allowed an extended time to make payment within four weeks with simple interest @9% since COVID-19 was prevalent at the relevant time and the assessee could not bona-fide make the payment due to the aforesaid reason and no prejudice would be caused to the Department.