This scheme is aimed at settling pending income tax disputes and is designed to reduce litigation and provide taxpayers with savings in time and resources.
Some key points are:
Eligible Cases: It applies to various forms of pending appeals or writ petitions as of July 22, 2024, including cases where objections have been filed before the Dispute Resolution Panel (DRP), but no directions have been issued yet.
Non-Eligible Cases: Certain cases, such as those involving assessments made due to searches under section 132/132A, undisclosed foreign income or assets, and cases involving prosecution under various laws, are excluded from the scheme.
Payment Structure: The amount payable under the scheme varies depending on the timing of the declaration:
100% of the disputed tax if declared before December 31, 2024. 110% if declared after January 1, 2025.
Forms and Timelines: Several forms (Form 1-4) are required for filing declarations, and timelines for completing payments are clearly outlined. For example, taxpayers should file Form-1 before December 31, 2024, to take advantage of the lower payment threshold.
Other Provisions: The document also includes details on how to handle issues like protective vs. substantive additions, cross-objections, penalty appeals, and adjustments related to TDS or TCS disputes.
This circular is important for understanding how to settle tax disputes under the DTVSV Scheme, 2024, and provides clarity on which cases qualify, how payments should be structured, and the forms and processes involved.