Saturday , March 14, 2026 |   12:50:17 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
I-T - Competent Authority shall issue tax withholding certificate, only after dilating upon nature of transaction and recording prima-facie opinion: HC (See Breaking News) TP - Interest u/s 234B and 234C is not leviable on incremental income declared in modified return filed pursuant to Advance Pricing Agreement: ITAT (See Breaking News) I-T - Deprtment is required to issue a tax withholding certificate, after dilating upon nature of transaction and recording prima-facie opinion: HC (See Breaking News) TP - Transfer pricing adjustment framed by invoking Section 92BA is unsustainable where the provisions were omitted w.e.f. 01.04.2017 & ceased to exist thereafter: ITAT (See Breaking News) TP - Mere broad functional similarity is insufficient for reliable analysis, even under Transactional Net Margin Method: ITAT (See Breaking News) TP - AMP expenses cannot be benchmarked independently once entity-level TNMM has been applied, as segregating such expenses would result in double counting & contravene transfer pricing rules: ITAT (See Breaking News) TP - A per settled legal position, incidental benefit to an AE does not convert routine AMP expenditure into an international transaction: ITAT (See Breaking News) TP - Once international transaction is covered by binding APA, tax authorities can't make a disallowance u/s 37(1) on basis that expenditure was not incurred wholly & exclusively for purpose of business: ITAT (See Breaking News) DTAA - Purpose of Art 25(1) of DTAA is limited to elimination of double taxation and cannot be interpreted to impose restrictions of domestic law on specific computational mechanism provided in Art 7(3) : ITAT SB (See Breaking News) I-T - Apportionment of contract price into different cost centers and milestones, as pre-requisite of tender conditions, does not automatically render those activities severable from main object of contract: ITAT (See Breaking News) I-T - If right to show cricket matches is confined to live telecast and payment made is only for matches held in series and not subsequent matches, such amount paid for transmission can't be considered as royalty: HC (See Breaking News) I-T - Once receipts fall within definition of FTS under DTAA as well as domestic law, it becomes immaterial whether assessee has PE in India or not: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >>
 

Vivad Se Vishwas Scheme - Order to remove difficulty issued
By TII News Service
Jan 20, 2025 , New Delhi

    
Untitled Document

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
NEW DELHI

NOTIFICATION NO

08/2025; Dated: January 20, 2025

S.O. 348(E) - WHEREAS, the Direct Tax Vivad Se Vishwas Scheme, 2024 was introduced vide the Finance (No.2) Act, 2024 (15 of 2024) and came into force with effect from the 1st day of October, 2024; WHEREAS, while implementing the said Scheme difficulties have arisen in situations where,––

(a) an order in case of a person had been passed on or before the specified date i.e. the 22nd day of July, 2024;

(b) the time for filing an appeal in respect of such order was available as on the said date;

(c) appeal in respect of such order was filed after the said date within the stipulated time as applicable for filing of such appeal; and

(d) aforesaid appeal is filed without any application for condonation of delay;

WHEREAS, section 98 of the said Finance (No.2) Act, 2024 provides that if any difficulty arises in giving effect to the provisions of the Scheme, the Central Government may, by Order, not inconsistent with the provisions of the Scheme, remove the difficulty;

NOW THEREFORE, in exercise of the powers conferred by sub-section (1) of section 98 of the Finance (No.2) Act, 2024, the Central Government hereby makes the following Order to remove the difficulty, namely:––

(i) in the case of such a person, aforesaid appeal shall be considered as pending as on the 22nd day of July, 2024 for the purposes of the said Scheme;

(ii) such a person shall be considered as an appellant for the purposes of the said Scheme;

(iii) in such a case, disputed tax shall be calculated on the basis of such appeal; and

(iv) the provisions of the said Scheme and the rules framed thereunder shall apply accordingly in such a case.

[F. No. 370153/01/2025-TPL]

(Pradeep Sharma)
Dy. Secy., Tax Policy & Legislative Division

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.