Cases where the High Court has passed an order in an appeal u/s 260A of the Act and time limit to file SLP has not expired. Whether such cases are covered?

In a case time limit for filing of appeal expired before 31 January 2020; and assessee has filed belated appeal post 31 January 2020 with a request to condone the delay in filing of appeal, whether the assessee is entitled to avail the benefit of the Scheme in such a case? Also, what will be eligibility status of the assessee who has filed belated appeal which is pending for admission as on 31 January 2020? Whether in such case assessee would be eligible even if appellate authority has dismissed the appeal as being time-barred by an order passed after 31 January 2020?

Assessment order is set aside under section 263 due to revision order passed by CIT and consequential order is not passed by the AO. ITAT appeal has been filed against the CIT 263 order and is pending as on 31 January 2020. Whether scheme can be availed for settling issues in the following scenarios:

a) Where order u/s 263 has been passed by the CIT with specific directions –

b) CIT 263 order has been passed with general directions from CIT –

c) CIT 263 order has been passed with general directions from CIT and the consequential AO order has been passed on 15 February 2020 (ie before filing the declaration) –

In a case, where section 263 revision notice is issued to the taxpayer and no revision order has been passed till 31 January 2020 but is passed later (say 15 February 2020 ie before filling the VSV declaration). Whether such an order is eligible for settlement under the VSV scheme?

Whether taxpayer is eligible to avail VSV where decision was orally pronounced by Court as on 31 January 2020, but formal appellate order was passed post 31 January 2020?

a) Whether taxpayer is eligible to avail VSV where matter was fully heard by appellate forum as on 31 January 2020, but appellate order passed post 31 January 2020 but before filing the declaration? Whether FAQ 50 (for giving effect to appellate order passed for comuting disputed tax liability) and FAQ 25 (for giving effect to rectification order passed for comuting disputed tax liability), will be applicable in this scenario as well?
b) If answer to the above is yes, whether disputed tax is to be computed after considering relief granted in appellate order?

Where draft order has been passed by the AO and no objections have been preferred to the DRP and time limit to pass the final assessment order has not expired. Whether such cases are covered?

5. Assessee wishes to settle year 1 and 2 under the appeal. Where year 1 is settled under VSV scheme it will result into refund (due to taxes paid earlier) and there is a demand in year 2.
A) Whether refund of year 1 can be adjusted against demand of year 2 while determining sum payable under VSV Scheme?
B) Whether any other crystallised refund from normal assessment can be adjusted against the demand for year 2 while determining sum payable under VSV Scheme?

ABC Ltd has got merged into XYZ Ltd on 1 April 2010. Both the companies have pending litigation.
a) Assuming both the companies have litigation for AY 2008-09 only. Whether for settlement for AY 2008-09, should all appeals of both the companies are to be considered together or both companies can file separate applications?
b) Assuming both the companies have multiple years in litigation. Will the answer be same as part a)
c) In case of death of a person or conversion of firm into LLP, whether same principle will apply?
d) In whose name and PAN declaration is to be filed, who could be signatory to sign the declaration, payment of disputed tax is made in whose name, how credit for prepaid taxes of amalgamating company be considered while computing disputed tax, etc.? Whether section 159 of the Income tax Act, 1961 (legal representative) will be applicable here?

In case of taxpayer, an addition has been made, whereby demand of Rs.10 lakh is raised including interest of Rs.3 lakh. The taxpayer has filed appeal before CIT(A), which is pending as on 31 January 2020. The taxpayer has paid the entire demand including interest due. If the taxpayer settles the matter under VSV Scheme and tax due under VSV is settled against the demand already paid by taxpayer, whether taxpayer will be eligible to get refund of tax (including interest)??