Supreme Court's Interpretation Overrules CBDT Circular for Settlement Eligibility Under VSV Act; FAQ No.59 Deemed Unlawful.

Eligibility of settlement under the VSV Act - It is also settled law that when the Supreme Court or High Court declare the law on a question arising for consideration, then the view expressed by the Supreme Court or the High Court has to be given effect to and not the circular issued by the CBDT - Consequently, the FAQ No.59 of Circular No.21/2020 dated 4th December, 2020 issued by CBDT to the extent it contemplates admission of appeal before filing of declaration as a condition precedent in order for the appeal to be treated as pending and to be eligible for settlement under the VSV Act is contrary to law. - HC .....

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