Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.

Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.

Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.

Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.

Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.

Facts: The appellants challenged the HCs decision affirming interest liability under MAT provisions (Section 115J of the Income Tax Act, 1961). The appellants sought to resolve the dispute under the Direct Tax Vivad Se Vishwas Scheme, 2024, which required appeals pending as of 22-07-2024 to be withdrawn subsequently. CBDT Circular No. 12 of 2024 clarified that taxpayers must withdraw appeals and provide proof with payment details to avail of scheme benefits.
Decision: The court held that as per Section 91(3) of the scheme, appeals must be withdrawn, and proof furnished along with payment intimation u/s 92(2). The appeals were disposed of as withdrawn, allowing the appellants to approach authorities for scheme benefits. The court clarified that the scheme required full settlement of disputes, disallowing partial resolution.