We would like to have your expert opinion on quarry regarding opting” Vivad Se Vishwas Scheme, 2020” in the matter of our one of the client. The facts are as under:
1. Assessment Year : 2007-08
2. Assessment Proceedings U/S 143(3) r.w.s 147 of the Act was completed by the Assessing Officer
3. An addition of Rs. 3,54,64,845/- was made
4. Aggrieved by the Assessment Order appeal before the CIT(Appeals) was made
5. CIT(Appeals) vide order dated 22.02.2019 granted relief of Rs. 3,36,91,602/-
6. Revised taxable Income Rs. 21,33,833/-
7. Net Demand of Rs. 8,24,150/- was raised by the Assessing Officer vide his order dated 28.11.2019 (Order giving the effect to CIT(Appeals) order – After adjusting prepaid tax
Gross Tax Liability Rs. 10,65,828/- Less: Prepaid Tax Rs. 2,45,575/-
8. Aggrieved by the CIT(Appeals) Order second appeal before ITAT was filed on 09.12.2019
9. Department also filed appeal against CIT Orders before ITAT
10. We have opted for Vivad Se Vishwas Scheme, 2020
11. Form No.1 & Form No.2 were accordingly filed on 20.03.2020
12. On the basis of Demand raised by the Assessing Officer as per order dated 28.11.2019 (order giving the effect of CIT(Appeals) Order) Rs. 4,20,473/- payable by the our client
13. On 06.05.2020 Appropriate Authority issued Form No.3 Rs. 60,90,768/- is payable under DTVSV, 2020
As the Assesses appeal is pending we have had opted Schedule-4 of the Form No.1 of DTVSV,2020. We would like to have your expert opinion what we will be correct amount payable under DTVSV,2020. For your ease and ready reference extract of Form No.1,2 & 3 of DTVSV,2020 are enclosed.