It was only after disposal of appeals by Tribunal that petitioners tried to file declarations . But those were not accepted as last date for filing declarations was over . On writ dismissing the petition the Court held that filing of declaration in terms of Vivad se Vishwas Act, is neither a judicial act nor a quasi-judicial act . It was intended as a one time measure for an eligible declarant to file declaration within prescribed period and avail benefits thereunder. Petitioners having filed declarations in third week of June, 2021 much after last date of filing declaration i.e. 31-3-2021 were not eligible to claim any benefit under Vivad se Vishwas Act. Declarations had rightly not been accepted
Talluri Vijay Rahul v. CBDT (2022) 288 Taxman 283/ (2023) 331 CTR 293/ 223 DTR 52 (Telangana)( HC)/Tellur Venkata Narayanamma ( Smt) (2022) 288 Taxman 283/ (2023) 331 CTR 293/ 223 DTR 52 (Telangana)(HC)
Direct Tax Vivad Se Vishwas Act, 2020
S. 4: Filing of declaration and particular to be furnished -Time Limits up to 31-3 -2021 – Appeal disposed of by Tribunal on 22-4-2021 – After disposal of appeal declaration was filed – Rejection of declaration is valid [ S. 2(1)(a), 3 , Art , 226 ]