This article provides a comprehensive analysis of the ITAT Delhi Bench ‘C’ decision concerning the withdrawal of an appeal by Pradeep Patil against ITO Ward 51(3) for the assessment year 2013-14. The appeal was withdrawn as the assessee opted for the Direct Tax Vivad Se Vishwas Act, 2020, aimed at reducing litigation.
The case revolves around an appeal filed by Pradeep Patil challenging the order of the Learned CIT(A)-35, New Delhi. The primary contention in the appeal was undisclosed prior to the decision to withdraw under the Vivad Se Vishwas Scheme, which facilitates the resolution of pending tax disputes.
On February 10, 2021, during a virtual hearing, Pradeep Patil, represented by Ms. Rashi Singhal, CA, formally withdrew the appeal. The withdrawal was supported by a certificate under Section 5(1) of The Direct Tax Vivad Se Vishwas Act, indicating the assessee’s choice to settle the dispute out of court. The Senior DR did not object to the withdrawal.
The withdrawal of the appeal marks a significant use of the Vivad Se Vishwas Scheme, reflecting the government’s intent to minimize litigation and provide taxpayers with a clear pathway to resolve disputes. This case serves as a pertinent example for other taxpayers considering similar resolutions.
The dismissal of the appeal as withdrawn showcases the practical application of the Vivad Se Vishwas Scheme in real-world scenarios, promoting a non-adversarial tax environment and encouraging settlements. This decision not only concludes the litigation for the involved parties but also sets a precedent for the effective resolution of tax disputes.
Pradeep Patil vs. ITO Ward 51(3) – Appeal Withdrawal for AY 2013-14
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