The Direct Tax Vivad se Vishwas Scheme, 2024 opened on 1 October 2024 for disputes pending as on 22 July 2024 and closed for declarations on 30 April 2025. You paid 100% of disputed tax if you were a new appellant declaring by the early cut-off, more if you were an old appellant or declared later, and interest, penalty and fee were settled at 25% to 35%.
The Direct Tax Vivad se Vishwas Scheme, 2024 was the second scheme of its kind. It came into operation on 1 October 2024 and was aimed at clearing the backlog of pending direct tax appeals by letting taxpayers pay the disputed tax and walk away from the interest and penalty.
Eligibility was fixed by reference to a single date. The dispute had to be pending as on 22 July 2024 before the Supreme Court, a High Court, the Income Tax Appellate Tribunal, the Commissioner or Joint Commissioner (Appeals), or the Dispute Resolution Panel. Writs and special leave petitions counted, as did cases where the DRP had issued directions but the final assessment order had not yet been passed, and revision applications pending under s.264.
The amount payable depended on two things: when you first went into appeal, and when you filed the declaration. A new appellant, meaning one whose appeal was filed after 31 January 2020, paid 100% of the disputed tax if the declaration was filed by the early cut-off, and 110% afterwards. An old appellant, whose appeal was pending before 31 January 2020, paid 110% by the early cut-off and 120% afterwards.
Where the dispute was only about interest, penalty or fee, the settlement figure was 25% of that amount for a new appellant declaring by the cut-off and 30% afterwards; and 30% for an old appellant declaring by the cut-off and 35% afterwards. A 50% reduction applied where the appeal had been filed by the tax authorities rather than the taxpayer, or where the taxpayer had already succeeded before a lower authority on the same issue and that had not been reversed.
The early cut-off was originally 31 December 2024. CBDT extended the date for determining the amount payable to 31 January 2025, so declarations filed up to that date attracted the lower figures. The scheme was then closed by CBDT notification F. No. 32/2025 / F. No. 370142/9/2025-TPL dated 8 April 2025, which fixed 30 April 2025 as the last date on which a declaration in respect of tax arrears could be filed with the designated authority.
The process ran through four forms. Form 1 was the declaration and undertaking, filed electronically. Form 2 was the certificate issued by the designated authority, determining the amount payable and requiring withdrawal of the appeal, to be issued within 15 days. Form 3 was the taxpayer's intimation of payment, filed within 15 days of Form 2. Form 4 was the designated authority's final order recording full and final settlement.
Several categories were excluded outright. Assessments made following a search under s.132 or s.132A, cases in which prosecution had been instituted, disputes involving undisclosed foreign income or assets, and assessments made on the basis of information received under an agreement referred to in s.90 or s.90A were all outside the scheme.
As at August 2026 the scheme is closed. It matters now only for taxpayers who did settle and are dealing with the consequences of Form 4 — the finality of the settlement, the withdrawal of the appeal, and the fact that the settled issue cannot be reopened by either side for that year.
For anyone who settled, the Form 4 order is the operative document: it closes the year on the settled issues and the withdrawn appeal cannot be revived. For anyone who did not, the scheme is a reminder that these windows are short, are fixed by a single eligibility date, and price delay explicitly — an old appellant declaring late paid 120% of the disputed tax against a new appellant's 100%.
I hold a Mauritius TRC. Can the department still deny me treaty relief on the capital gains?
I paid advance tax for the year but had not filed my return when the search took place. Can the department still call that income undisclosed?
We outsource back-office work to our Indian subsidiary. Does that give us a permanent establishment in India?
My protocol has an MFN clause and I applied the lower rate India later agreed with an OECD member. Was I entitled to?
The Commissioner refused to waive the interest on my demand because I own property worth crores. Is owning assets an answer to genuine hardship?
The assessment order charges interest under s.215 (or s.217, or s.139(8)). Can I appeal against the interest, and if not, how do I get it reduced?
When must the satisfaction note be recorded before proceedings are taken against a third party?
I am a foreign company on a turnkey contract. I fabricated the platform abroad and only installed it in India. Can the Department tax the offshore fabrication profit because the contract was one indivisible whole?
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