Re: Show Cause Notice for Penalty

My client has opted for Vivad vishwas scheme and have completed all formalities and also obtained Form 3 i.e. A Certificate u/s.5(1) of Direct Tax VIVAD VISHWAS ACT,2020. Even then, Show cause notice for penalty U/s. 271(1)(c) seved on him
Please give your valuable suggetions

The show cause notice is bad in law after receipt of  certificate . The assessee may write to the Assessing officer to drop the penalty proceedings  as the issue is settled under VsV.    Please refer Circular No 9/2020 dt 22 -4 -20200,   Q. No. 45 and answer ,  it is specifically stated that As per section  6 subject to the provisions of  section  5 , the DA shall not institute any proceedings in respect of an offence , or impose or levy any penalty ; or charge any interest under the Income -tax Act in respect of tax arrears. This shall be reiterated in the order under section 5 (2) passed by DA .    

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