Vivad se Vishwas Scheme 2020...o Analysis of whether to File Declaration under the Scheme Points for Discussion CNK 2 o Finance Minister’s Budget 2020 Speech o No Dispute but Trust

Gautam Nayak

Chartered Accountant

Vivad se Vishwas Scheme 2020Bombay Chartered Accountants’ Society

21st April 2020

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o Background

o Key Definitions

o Eligibility under the Scheme

o Exclusions from the Scheme

o Issues re Eligibility under the Scheme

o Amount Payable under the Scheme

o Issues re Amount Payable under the Scheme

o Procedure under the Scheme

o Consequences of Settlement under the Scheme

o Analysis of whether to File Declaration under the Scheme

Points for Discussion

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o Finance Minister’s Budget 2020 Speech

o No Dispute but Trust Scheme – ‘Vivad Se Vishwas’Scheme

o In the past our Government has taken several measures to reduce tax litigations.In the last budget, Sabka Vishwas Scheme was brought in to reduce litigation inindirect taxes. It resulted in settling over 1,89,000 cases. Currently, there are4,83,000 direct tax cases pending in various appellate forums i.e. Commissioner(Appeals), ITAT, High Court and Supreme Court. This year, I propose to bring ascheme similar to the indirect tax Sabka Vishwas for reducing litigations even inthe direct taxes.

o Under the proposed ‘Vivad Se Vishwas’ scheme, a taxpayer would be required topay only the amount of the disputed taxes and will get complete waiver of interestand penalty provided he pays by 31st March, 2020. Those who avail this schemeafter 31st March, 2020 will have to pay some additional amount. The scheme willremain open till 30th June, 2020.

o Taxpayers in whose cases appeals are pending at any level can benefit from this scheme. I hope that taxpayers will make use of this opportunity to get relief from vexatious litigation process.

Background

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o The Direct Tax Vivad se Vishwas Bill, 2020 introduced in Lok Sabha on 5th February 2020

o Notice for moving amendments to Bill given on 14th February 2020

o Passed by Lok Sabha on 4th March 2020

o Passed by Rajya Sabha on 13th March 2020

o Received assent of President and notified on 17th March 2020

o Clarifications on provisions given in form of FAQs vide Circular No 7 of 2020 dated 4th March 2020

o The Direct Tax Vivad Se Vishwas Rules, 2020, setting out the procedures and giving the relevant forms, notified on 18th March 2020

o Instructions for filling up forms also issued on same day

o Systems and Procedures for e-filing forms notified by DGIT(Systems) on 19th

March 2020 vide Notification No 12 of 2020

o Press Release on 24th March 2020 for extension of date for lower payment from 31st March to 30th June – enacted through The Taxation And Other Laws (Relaxation Of Certain Provisions) Ordinance, 2020 on 31st March 2020

Background

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o Specified Date – 31st January 2020

o Disputed Income - in relation to an assessment year, means the whole or so much of the total income as is relatable to the disputed tax

o Disputed Tax – in relation to an AY or FY, the income-tax, including surcharge& cess, (amount of tax) payable by the appellant, as computed hereunder:

o where any appeal/WP/SLP is pending before the appellate forum as on the specified date, the amount of tax that is payable by the appellant if such appeal/WP/SLP was to be decided against him

o where an order in an appeal/WP has been passed by the appellate forum on or before the specified date, and the time for filing appeal/SLP against such order has not expired as on that date, the amount of tax payable by the appellant after giving effect to the order so passed

o where the order has been passed by the AO on or before the specified date, and the time for filing appeal against such order has not expired as on that date, the amount of tax payable by the appellant in accordance with such order;

Key Definitions

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o where objection filed by the appellant is pending before the DRP u/s 144C as on the specified date, the amount of tax payable by the appellant if the DRP was to confirm the variation proposed in the draft order

o where DRP has issued any direction u/s 144C(5) and the AO has not passed the order under sub-section (13) of that section on or before the specified date, the amount of tax payable by the appellant as per the assessment order to be passed by the AO under sub-section (13)

o where an application for revision u/s 264 is pending as on the specified date, the amount of tax payable by the appellant if such application for revision was not to be accepted

o Where CIT(A) has issued notice of enhancement u/s 251 on or before the specified date, disputed tax shall be increased by the amount of tax pertaining to issues for which notice of enhancement has been issued

o where the dispute in relation to an AY relates to reduction of tax credit u/s 115JAA or 115D (115JD?) or any loss or depreciation computed thereunder, appellant shall have an option either to include the amount of tax related to such tax credit or loss or depreciation in the amount of disputed tax, or to carry forward the reduced tax credit or loss or depreciation, in such manner as may be prescribed.

Key Definitions

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o tax arrear means,—

(i) the aggregate amount of disputed tax, interest chargeable or charged on such disputed tax, and penalty leviable or levied on such disputed tax; or

(ii) disputed interest; or

(iii) disputed penalty; or

(iv) disputed fee,

as determined under the provisions of the I.T. Act

o disputed interest means the interest determined in any case under the

provisions of the I.T Act, 1961, where—

(i) such interest is not charged or chargeable on disputed tax;

(ii) an appeal has been filed by the appellant in respect of such interest.

o disputed fee means the fee determined under the provisions of the IT Act, 1961 in respect of which appeal has been filed by the appellant;

Key Definitions

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o disputed penalty means the penalty determined in any case under the

provisions of the I.T. Act, 1961, where—

(i) such penalty is not levied or leviable in respect of disputed income or

disputed tax, as the case may be;

(ii) an appeal has been filed by the appellant in respect of such penalty

o appellate forum means the SC/HC/ITAT/CIT(A)

o appellant means—

(i) a person in whose case an appeal/WP/SLP has been filed either by him or by the IT authority or by both, before an appellate forum and such appeal or petition is pending as on the specified date;

(ii) a person in whose case an order has been passed by the AO, or an order has been passed by the CIT(A)/ITAT in an appeal, or by the HC in a WP, on or before the specified date, and the time for filing any appeal or SLP against such order by that person has not expired as on that date;

(iii) a person who has filed his objections before the DRP u/s 144C and the DRP has not issued any direction on or before the specified date;

Key Definitions

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(iv) a person in whose case the DRP has issued direction u/s 144C(5) and the AO has not passed any order under sub-section (13) of that section on or before the specified date;

(v) a person who has filed an application for revision u/s 264 and such application is pending as on the specified date

Key Definitions

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oHas to fall within the definition of declarant

o Declarant can file declaration only if there is tax arrear, i.e. disputed tax, disputed interest, disputed penalty or disputed fee

o not necessary that tax still payable or outstanding on specified date

o CBDT FAQ No 5 - appeals in which appellant has already paid the disputed demand either partly or fully are also covered

o CBDT FAQ No 9 - Vivad se Vishwas can be availed by the appellant irrespective of whether the tax arrears have been paid either partly or fully or are outstanding

o Needs to fall within the definition of appellant

o Should not fall under class of cases not covered by the VsV Act – s. 9

Eligibility under the Scheme

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1. Tax arrear of A.Y. in respect of which assessment made under s.143(3)/144/153A/ 153C on the basis of search initiated under section 132/132A, if the amount of disputed tax exceeds Rs 5 crore;

o Limit of Rs 5 crore to be seen vis-à-vis each AY – some years may be eligible, others may not be – CBDT FAQ No 6

o Disputed tax does not include interest or penalty – only tax, surcharge and cess

2. Tax arrear of A.Y. in respect of which prosecution has been instituted on or before the date of filing of declaration

o Not eligible even if prosecution launched not for concealment, but for some other default (e.g. avoiding payment of tax demand, non-payment of TDS on time)

o What is date of institution of prosecution – date of issue of show cause notice by CIT, date of sanction by CIT, date of filing complaint by AO or date of issue of first summons by court? CBDT FAQ No 22 – eligible if only notice for initiation of prosecution issued

3. Tax Arrear relating to any undisclosed income from a source located outside India or undisclosed asset located outside India

4. Tax arrear of Assessment/reassessment made on the basis of information received under DTAA, if it relates to any tax arrear

o

Ineligibility under the Scheme – S.9

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4. any person in respect of whom an order of detention has been made underCOFEPOSA, 1974 on or before the filing of declaration, if such order of detentionhas not been revoked or set aside

5. any person in respect of whom prosecution for any offence punishable underUnlawful Activities (Prevention) Act, 1967, Narcotic Drugs and PsychotropicSubstances Act, 1985, the PoCA, 1988, PMLA, 2002, the Prohibition of BenamiProperty Transactions Act, 1988 has been instituted on or before the filing of thedeclaration or such person has been convicted of any such offence punishableunder any of those Acts

6. any person in respect of whom prosecution has been initiated by an IT authorityfor any offence punishable under the provisions of the IPC or for the purpose ofenforcement of any civil liability under any law for the time being in force, on orbefore the filing of the declaration or such person has been convicted of any suchoffence consequent to the prosecution initiated by an IT authority

7. any person notified u/s 3 of the Special Court (Trial of Offences Relating toTransactions in Securities) Act, 1992 on or before the filing of declaration

Ineligibility under the Scheme – S.9

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o Can only some issues be settled under the scheme, while appeal continues for others?

o CBDT FAQ No 11 - no provision to settle part of a pending dispute in relation to an appeal or writ or SLP for an assessment year. For one pending appeal, all the issues are required to be settled and if anyone of the issues makes the declaration invalid, no declaration can be filed.

o CBDT FAQ No 14 - Picking and choosing issues for settlement of an appeal is not allowed. With respect to one order, the appellant must chose to settle all issues and then only he would be eligible to file declaration.

o Do all appeals for an assessment year have to be settled?

o Both assessee’s as well as Department’s? Option – CBDT FAQ No 40 – to indicate in declaration form

o On assessment, reassessment as well as penalty? CBDT FAQ No 19 – in cases of appeals pending against both assessment as well as reassessment, has an option to settle either of the two appeals or both appeals for the same assessment year. If he decides to settle both appeals then he has to file only one declaration form

Questions re Eligibility under the Scheme

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o Penalty without settling quantum, where both appeals pending – CBDT FAQ No 8 -

not possible for the appellant to apply for settlement of penalty appeal only, when the appeal on disputed tax related to such penalty is still pending – required to pay relevant percentage of disputed tax only

o TDS/TCS disputes – can also be settled – CBDT FAQ No 15

o Disputes in relation to taxes other than those under IT Act not covered – CBDT FAQ No 18 – WT, CTT and Equalisation Levy not covered


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o Appeal/WP/SLP pending or time limit for filing appeal/SLP not expired on specified date – whether eligible in following cases

o If time limit for filing expires after specified date and appeal filed in time or even not filed – eligible – CBDT FAQ No 23

o If time limit for filing expired, but belated appeal/SLP filed by assesee

o before specified date where no condonation before specified date

o before specified date where condonation allowed after specified date

o before specified date where refusal of condonation before specified date, where time limit for further appeal not expired

o after specified date where no condonation till date

o after specified date where condonation allowed

o If time limit for filing expired, but belated appeal/SLP filed by tax department

o Problem if belated appeal filed after end of scheme

o If MA/rectification application filed and pending

o If assessment set aside by ITAT – CBDT FAQ No 7 - yes, except where de novo assessment directed


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o If appeal/WP/SLP decided in favour of Department after 31st January 2020

o If appeal filed before HC but admission pending – CBDT FAQ No 24 - eligible

o If application pending before AAR – CBDT FAQ No 3 – No. If writ pending against AAR ruling, yes, provided AAR has determined total income

o If application pending before Settlement Commission – not eligible

o If WP filed against order of Settlement Commission – eligible

o If WP filed against notice of reassessment u/s 148, where no reassessment order passed – not eligible as no tax determined – CBDT FAQ No 12

o If only reassessment notice issued, but no reassessment order passed

o If only penalty notice issued, but no penalty order passed

o Appeals against protective assessment order

o CBDT FAQ No 35 – if substantive addition settled under VsV scheme, AO to pass rectification order deleting protective addition


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oOrder passed by AO and time limit for filing appeal not expired

o Whether intimation u/s 143(1) received from CPC also covered?

o Vijay Gupta v CIT 386 ITR 643 (Del) - Since section 264 uses the expression 'anyorder', it would imply that the section does not limit the power to correct errorscommitted by the subordinate authorities but could even be exercised where errorsare committed by assessees. It would even cover situations where the assesseebecause of an error has not put forth a legitimate claim at the time of filing thereturn and the error is subsequently discovered and is raised for the first time in anapplication under section 264

oObjections Filed before DRP and no directions issued, or directions issued but no consequential order passed by AO on specified date

o If draft assessment order issued on 31st December 2019, but assessee preferred appeal route – final assessment order passed on 14th February 2020, and appeal filed in March 2020 – CBDT FAQ No 16 – eligible


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oPerson who has filed Revision Application under s.264 which is pending on specified date

o Cases of belated applications u/s 264 where delay not condoned till specified date – subsequent condonation/refusal of condonation

o Pending proceedings u/s. 263 – not covered

o Revision order passed under s.263 directing addition/readjudication by AO – time limit for filing ITAT appeal not expired – not covered

o Application for waiver of interest to CIT – not a revision application u/s 264 nor appeal – CBDT FAQ No 13 – not eligible


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Amount Payable under the Scheme – s.3

Nature of Tax Arrear Amount Payablebefore 30th June 2020

Amount Payableafter 30th June 2020

If aggregate of disputed tax, interest chargeable/charged and penalty leviable/levied

100% of disputed tax

110% of disputed tax

If aggregate of tax, interest or penalty determined in assessment on basis of search u/s 132/132A

125% of disputed tax(25% not exceeding interest and penalty)

135% of disputedtax(35% not exceeding interest and penalty)

If relates to disputed interest, disputed penalty or disputed fee

25% of disputedinterest, penalty or fee

35% of disputedinterest, penalty or fee

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o If appeal/WP/SLP is by tax authority, amount payable is 50% of amt as per table

o If assessee’s appeal to CIT(A)/objections before DRP, and issue covered in his favourby unreversed ITAT/HC decision in his own case, amount payable is 50% of amt as per above table

o If assessee’s appeal before ITAT, and issue covered in his favour by unreversed HC decision in his own case, amount payable is 50% of amt as per above table

o What if SC decision in assessee’s favour - no dispute now with regard to that issue and he need not settle that issue – CBDT FAQ No 37

o Also if favourable ITAT appeal in own case, and ITAT appeal being settled – CBDT FAQ No 39

o CBDT FAQ No 17 – If CIT(A) has issued enhancement notice, disputed tax to include tax on proposed enhanced income

Amount Payable under the Scheme

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o Rule 11 - Where dispute includes issues covered in favour of declarant, disputed taxin respect of such issues shall be amount, which bears to tax, including surchargeand cess, payable on all the issues in dispute, the same proportion as the disputedincome in relation to issues covered in favour of declarant bear to the disputedincome in relation to all the issues in dispute

oCBDT FAQ No 10 - If the disputed fee pertains to a year in which there is disputedtax, the settlement of disputed tax will not settle the disputed fee. If assessee wantsto settle disputed fee, he will need to settle it separately


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o Rule 9 - If dispute in relation to an AY relates to reduction in loss/unabsorbed depreciation to be carried forward, declarant has option to:

i. include the tax, including surcharge and cess, payable on the amount by whichloss/unabsorbed depreciation is reduced in the disputed tax and carry forward theloss/unabsorbed depreciation by ignoring such amount of reduction inloss/unabsorbed depreciation, or

ii. carry forward the reduced amount of loss or unabsorbed depreciation

o If option (ii) is exercised:

a. liable to pay tax, including surcharge and cess, along with interest, if any, as aconsequence of carrying forward the reduced amount of loss or unabsorbeddepreciation in subsequent years;

b. wdv of block of asset on the last day of the year, in respect of which unabsorbeddepreciation has been reduced, shall not be increased by the amount of reduction inunabsorbed depreciation;

c. In eligible search cases, 1.25 times of loss/unabsorbed depn to be reduced

d. if such reduction is related to issues covered in favour of declarant, reduction of 50%loss/unabsorbed depn in non-search cases, reduction of 5/8th in eligible search cases


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o Rule 10 – If dispute in relation to an AY relates to reduction in MAT to be carried forward, declarant has option to:

i. include the amount by which MAT credit to be carried forward is reduced indisputed tax and carry forward the MAT credit by ignoring such amount ofreduction, or

ii. carry forward the reduced MAT credit

o If option (ii) is exercised:

a. liable to pay tax, including surcharge and cess, along with interest, if any, as aconsequence of carrying forward reduced MAT credit in subsequent years;

b. In eligible search cases, 1.25 times of MAT credit to be reduced

c. if such reduction is related to issues covered in favour of declarant, reduction of 50%MAT credit in non-search cases, reduction of 5/8th in eligible search cases


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o Disputed tax – gross tax liability or net additional tax demand?

o CBDT FAQ No 26 – example

o Credit available for taxes paid post-assessment

o CBDT FAQ No 29 – Credit for taxes paid against the disputed tax before filingdeclaration shall be available to the declarant

o What if entire assessment demand (tax & interest) paid – would interest paid berefunded?

o Expl to s.7 - where declarant had paid any amount in respect of his tax arrear beforefiling declaration u/s 4(1) which exceeds amount payable under section 3, entitled torefund of such excess amount, but not entitled to interest on such excess amount u/s244A - time limit for issue of refund?

o 2 years disputes being settled – refund in 1 year, payment in another – adjustmentpossible?

oAmount payable if assessee has filed appeal to ITAT, Dept has also filed appeal?

o Amount payable if assessee has filed appeal to ITAT, Dept has filed cross objections?

o Amount payable if Dept has filed appeal to ITAT, assessee has filed cross objections?

Amount Payable under the Scheme - Issues

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o Amount payable if both assessment as well as reassessment appeals being settled

o CBDT FAQ No 19 - disputed tax in this case would be the aggregate amount of disputedtax in both appeals

o What if some issue is common to both appeals?

o Amount payable if appeal to CIT(A) on some issues, and rectification application alsofiled with AO:

o If issues in rectification are also taken in appeal

o If issues in rectification are not taken in appeal

o CBDT FAQ No 25 - disputed tax in such cases would be calculated after giving effect tothe rectification order passed, if any.

o Amount payable if assessment demand paid and refund received on success insecond appeal, along with interest u/s 244A, now Dept appeal to HC/SC pending

oWhether interest received u/s 244A to be refunded?

oWhat about s.244A interest in respect of interest part of demand which was paid?


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o CBDT FAQ No 36 - ITAT decided 3 issues in favour of assessee, 2 against – time limitfor filing appeal to HC not expired on specified date. Appellant has a choice, he canonly settle his deemed appeal on 3 issues, or he can settle department deemedappeal on 2 issues or he can settle both. If he decides to settle only his deemedappeal, then department would be free to file appeal on the 2 issues (where theassessee has got relief) as per the extant procedure laid down and directions issuedby the CBDT


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o Declaration to be filed under s.4(1) to designated authority (CIT) in Form 1

o Declarant to furnish an undertaking under s. 4(5) in Form 2 along with thedeclaration - waiving his right, whether direct or indirect, to seek or pursue anyremedy or any claim in relation to the tax arrear which may otherwise be available tohim under any law for the time being in force, in equity, under statute or under anyagreement entered into by India with any country whether for protection ofinvestment or otherwise

oBoth Forms 1 and 2 to be signed and verified by the declarant or any personcompetent to verify the return of income on his behalf u/s 140 – to be done inconjunction as a single submission

o CIT to issue an acknowledgement on receipt of declaration

o Within 15 days from date of receipt of declaration, CIT, by order u/s 5(1), todetermine amount payable by the declarant and grant a certificate to the declarantcontaining particulars of the tax arrear and the amount payable after suchdetermination, in Form 3

Procedure under the Scheme

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oOrder passed u/s 5(1) to be conclusive as to the matters stated therein - no mattercovered by such order shall be reopened in any other proceeding under the I.T. Act orunder any other law for the time being in force or under any agreement

o Can mistake in order be rectified or revised by CIT before payment? CBDT FAQ No 46 –CIT can rectify any apparent errors – FAQ No 47 – cannot be challenged in court

o Upon the filing the declaration, any appeal pending before the ITAT or CIT (A), inrespect of the disputed income or disputed interest or disputed penalty or disputedfee and tax arrear shall be deemed to have been withdrawn from the date on whichcertificate u/s 5(1) is issued by the CIT

oDeclarant to withdraw any appeal/WP/SLP before HC/SC in relation to tax arrear withleave of the Court, and any proceeding for arbitration, conciliation or mediation underany agreement

oDeclarant to pay the amount determined within 15 days of date of receipt of thecertificate and intimate the details of such payment to the CIT in Form 4

o Along with Form 4, proof of withdrawal of appeal/WP/SLP or arbitration/conciliation/mediation proceeding to be filed


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o CIT to pass an order u/s 5(2) in Form 5 stating that declarant has paid amountdetermined u/s 5(1)

o Order for full and final settlement of tax arrear – grant of immunity

o Declaration presumed never to have been made if:

(a) any material particular furnished in the declaration is found to be false at any stage;

(b) the declarant violates any of the conditions referred to in this Act;

(c) the declarant acts in any manner not in accordance with the undertaking given

o Even after issue of the certificate u/s 5(2)?

o In such cases, all proceedings and claims withdrawn u/s 4 and all consequencesunder the I.T. Act against the declarant deemed to have been revived

o Whether only Dept’s appeals or assessee’s appeals also?

oWhat if the declarant does not make payment within 15 days of receipt of thecertificate u/s 5(1)?

o CBDT FAQ No 49 – declaration would be null and void

o CBDT FAQ No 43 - no appeal required to be withdrawn before grant of certificate by CIT– s.4(2) – deemed withdrawal?


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o s. 4(7) - No appellate forum or arbitrator, conciliator or mediator shall proceed todecide any issue relating to the tax arrear mentioned in the declaration in respect ofwhich an order has been made u/s 5(1) by the CIT or the payment of sumdetermined under that section – including Dept appeals

o s. 5(3) - no matter covered by such order shall be reopened in any other proceedingunder the I.T. Act or under any other law for the time being in force or under anyagreement, whether for protection of investment or otherwise, entered into by Indiawith any other country or territory outside India

o s. 6 – CIT shall not institute any proceeding in respect of an offence; or impose orlevy any penalty; or charge any interest under the Income-tax Act in respect of taxarrear

o Also AO will not do so?

o Immunity also available to directors/partners (TDS offences)?

o Form 5 - the immunity is granted subject to the provisions contained in the Act,from instituting any proceeding for prosecution for any offence under the Income-tax Act or from the imposition of penalty under the said enactment [as per section6 of the Act], in respect of the tax arrear

o

Consequences of Settlement under the Scheme

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o If addition made on 2 issues, appeal was pending only on one issue, which issettled under scheme. Interest and penalty waiver only for disputed issue settledunder scheme, not for the undisputed issue – CBDT FAQ No 38

o s. 7 – amount paid in pursuance of declaration u/s 4 not refundable under anycircumstances

oWhat if declaration held to be invalid because of late payment of amountdetermined u/s 5(1) or if presumed never to have been made due to subsequentviolations? Can tax be retained without authority of law?

o In context of KVSS, similar provision

o Patchala Seethramaiah v. CIT 241 ITR 287 (AP) - revenue was not entitled to retainamount of tax paid under non-est declaration

o Save as otherwise expressly provided in s 5(3) or s 6, shall not be construed asconferring any benefit, concession or immunity on the declarant in any proceedingsother than those in relation to which declaration has been made


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oMaking a declaration shall not amount to conceding the tax position – not lawful forthe IT authority/declarant to contend that the declarant/IT authority has acquiescedin the decision on the disputed issue by settling the dispute

oWhere assessee settles TDS appeal, will deductee get TDS credit – yes, as on thedate of settlement of dispute by the deductor and interest as applicable to deducteeshall apply – CBDT FAQ No 30

o Where assessee settles TDS appeal, will he get consequential relief of expenditureallowance under proviso to section 40(a)(i)/(ia) – entitled to get consequential reliefof allowable expenditure in the year in which tax was required to be deducted –CBDT FAQ No 31 – rectification?

o Income assessed under MAT – dispute relating to book profits settled under VsVscheme – whether enhanced MAT credit available for carry forward?

o If dispute relating to TP settled for AY 2017-18 onwards, secondary adjustmentwould apply – CBDT FAQ No 54


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o What are the assessee’s ultimate chances of success in appeal

o How long will it take to achieve closure of the dispute

o What would be the potential ultimate liability along with interest if the assesseewere to lose the appeal

o What would be the likelihood of penalty being upheld if the assessee were to losethe appeal

o What is the risk of prosecution

o Impact of other pending appeals

o What would be the legal costs of fighting the matter and the penalty till the end

o Would the deduction even otherwise be available for later years

o e.g. capital expenditure and depreciation/s.35D

o What would be the amount payable under the scheme

o Is the Dept’s appeal pending or the assessee’s appeal

o Is the issue covered by an ITAT/HC order in the case of the assesse

o Is the amount already paid – would declaration result in refund?

Analysis to be Undertaken

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Documents

Vivad se Vishwas Scheme 2020...o Analysis of whether to File Declaration under the Scheme Points for Discussion CNK 2 o Finance Minister’s Budget 2020 Speech o No Dispute but Trust