TMI Blog2021 (6) TMI 1168X X X X Extracts X X X X X X X X Extracts X X X X ..... tter requires examination. Accordingly, issue notice. Counter-affidavit will be filed within the next four weeks. Rejoinder thereto, if any, will be filed before the next date of hearing. Revenue will accept Forms 1 2 filed by the petitioner, on 23.03.2021, along with 100% of the disputed tax. Mr. Aggarwal says that, according to the petitioner, ₹ 16,81,546/- is payable towards 100% of the disputed tax . The respondent, therefore, pending the adjudication of the petition, without prejudice to its rights and contentions, will accept Forms 1 2 with 100% of the disputed tax. In case, according to the respondent/revenue, 100% of the disputed tax figure, is at variance with the aforementioned amount, the same will be indicat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... petitioner, has, broadly, taken us through the record. 3.1. It appears that the petitioner had filed Forms 1 and 2, under the Direct Tax Vivad se Vishwas Act, 2020 (in short 2020 Act ) twice, i.e., on 10.03.2021 and 23.03.2021, however, both times, it was rejected. The first time, it was rejected was on 23.03.2021. The petitioner refiled Forms 1 and 2 on the same date, i.e., 23.03.2021, which stood rejected on 05.04.2021. 3.2. It appears that the principal reason given for the rejection of the aforementioned forms is that the petitioner s revision application filed under Section 264 of the Income Tax Act, 1961 (in short 1961 Act ) was not pending as on the specified date, i.e., 31.01.2020. 3.3. It is Mr. Aggarwal s contention tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of these orders. 4. To our minds, the matter requires examination. 5. Accordingly, issue notice. Mr. Abhishek Maratha accepts service on behalf of respondent/revenue. 5.1. Counter-affidavit will be filed within the next four weeks. Rejoinder thereto, if any, will be filed before the next date of hearing. 6. Given the aforesaid facts and circumstances, the respondent/revenue will accept Forms 1 2 filed by the petitioner, on 23.03.2021, along with 100% of the disputed tax. Mr. Aggarwal says that, according to the petitioner, ₹ 16,81,546/- is payable towards 100% of the disputed tax . (See page 126 of the paper book.) 6.1 The respondent, therefore, pending the adjudication of the petition, without prejudice to its r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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