TMI Blog2020 (11) TMI 143X X X X Extracts X X X X X X X X Extracts X X X X ..... nt developments. The Government of India enacted the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) to provide for resolution of disputed tax and for matters connected therewith or incidental thereto. The Act of the Parliament received the assent of the President on 17th March 2020 and published in the Gazette of India on 17th March 2020. In terms of the said Act, the assessee has been given an option to put an end to the tax disputes, which may be pending at different levels either before the First Appellate Authority or before the Tribunal or before the High Court or before the Hon'ble Supreme Court of India. The assessee is given liberty to restore this appeal in the event the ultimate decision to be taken on the declara ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the Assessment Year 2001-02. 2.The following Substantial Questions of Law have been raised for consideration. 1.Whether the Appellate Tribunal is correct in law in sustaining the disallowance of expenses for earning the contract income even after the acceptance of the charge of income by the recipient in the reassessment passed in their hands which divergent stand would negate the rule of consistency as well as the Doctrine of 'Fair Procedure'? 2.Whether the Appellate Tribunal is correct in law in overlooking the reassessment framed in the hands of the recipient in booking the income earned from the Appellant for assisting them in the execution of the contract work which amounts were claimed as expenses even though un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x disputes, which may be pending at different levels either before the First Appellate Authority or before the Tribunal or before the High Court or before the Hon'ble Supreme Court of India. Under Section 2(j) disputed tax has been defined. In terms of Section 3, where a declarant means a person, who files a declaration under Section 4 on or before the last date files a declaration to the designated authority in accordance with the provisions of Section 4 in respect of tax arrears, then, notwithstanding anything contained in the Income Tax Act or any other law for the time being in force, the amount payable by the declarant shall be determined in terms of Section 3(a-c) thereunder. 7.The First Proviso to Section 3 states that in ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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