This Tax Alert summarizes the key features of the proposed Direct Tax Vivad Se Vishwas Scheme, 2024 (2024 Scheme) in the Finance (No. 2) Bill, 2024 (FB 2024) as part of Union Budget 2024 announced by the Hon’ble Finance Minister on 23 July 2024.
The 2024 Scheme enables settlement of disputes pending as on 22 July 2024 under Income-tax Laws (ITL). It draws flavor from the previous Direct Tax Vivad Se Vishwas Act, 2020 (2020 Scheme) in the applicability, procedure and manner of settlement of dispute. The date from which the taxpayers can begin to settle their disputes as well as the sunset date, are yet to be notified.
The 2024 Scheme can be availed by taxpayers in various cases such as; Where (i) appeals/writ petition/special leave petition (SLP) relating to disputed tax, interest, penalty or fee is pending before the appellate authorities/High Court (HC) /Supreme Court (SC) ; (ii) objections are filed before the Dispute Resolution Panel and the DRP is yet to issue directions, (iii) DRP has issued directions, however, the tax authority is yet to pass an assessment order in conformity with such directions, (iv) revision application is filed by the taxpayer before the Commissioner.
In terms of the 2024 scheme, a taxpayer may settle its eligible disputes by making payment of the amounts as determined by the Designated Authority (DA) as per the 2024 Scheme.
