Direct Tax Vivad se Vishwas Scheme, 2024

Introduction

The Direct Tax Vivad se Vishwas (DTVSV) Scheme, 2024 was introduced by Union Finance Minister Nirmala Sitharaman in the Union Budget 2024–25. The scheme offers a simplified mechanism for resolving pending income tax disputes, aiming to reduce the litigation burden on both taxpayers and the tax administration. This article outlines the key features of the DTVSV Scheme, 2024, along with the relevant forms and procedures for accurate filing.

Overview of the DTVSV Scheme, 2024

The Direct Tax Vivad se Vishwas (DTVSV) Scheme, 2024 came into effect on October 1, 2024. The scheme provides a reduced settlement amount for a new appellant compared to an old appellant. Additionally, taxpayers who submit their declarations on or before December 31, 2024, are entitled to a lower settlement amount than those who file after this deadline.

The DTVSV Scheme aims to minimize income tax litigation by enabling taxpayers to resolve pending income tax appeals, writs, and petitions before various appellate authorities—including the High Courts and the Supreme Court—as of July 22, 2024.

Latest Update on the Vivad se Vishwas (DTVSV) Scheme

Deadline to File Declaration Under the DTVSV Scheme: April 30, 2025
The Central Board of Direct Taxes (CBDT) issued a notification on April 8, 2025, extending the last date for filing declarations under the Vivad se Vishwas Scheme, 2024 to April 30, 2025.
This extension applies to all declarants seeking to settle direct tax disputes in accordance with Section 90 of the Finance (No. 2) Act, 2024. As per the notification, all declarations must be submitted to the designated authority on or before the specified date to avail the benefits offered under the scheme.

Eligibility Criteria for the DTVSV Scheme, 2024

To qualify for the Direct Tax Vivad se Vishwas (DTVSV) Scheme, 2024, taxpayers must meet one or more of the following conditions as of July 22, 2024:

Pending Appeals: Taxpayers with appeals pending before the Commissioner of Income Tax (Appeals) [CIT(A)], Income Tax Appellate Tribunal (ITAT), High Court, or Supreme Court.
Objections before the DRP: Taxpayers who have filed objections with the Dispute Resolution Panel (DRP) under Section 144C of the Income Tax Act, where the DRP has not yet issued directions to the Assessing Officer (AO).
DRP Directions Awaiting Final Order: Taxpayers for whom the DRP has issued directions to the AO, but the final assessment order is still pending.
Pending Revision Applications: Taxpayers with revision applications pending under Section 264 of the Income Tax Act.

Forms under the DTVSV Scheme, 2024

1. The DTVSV Scheme involves four prescribed forms to streamline the settlement process:
  Form-1: Declaration and Undertaking by the Declarant
  Taxpayers must use Form-1 to declare their intent to settle a tax dispute and provide an undertaking to withdraw any related legal proceedings.
  - A separate Form-1 must be filed for each dispute.
  - If both the taxpayer and the tax department have filed appeals, writs, or special leave petitions concerning the same order, a single Form-1 can be used.
  - The declaration must be verified by the taxpayer or an authorized person who can verify their income tax return.
  - Upon submission, the designated authority will issue an electronic acknowledgment of Form-1.
  Form-2: Certificate Issued by the Designated Authority
  After reviewing Form-1, the designated authority issues Form-2, certifying the particulars of the tax arrear and determining the amount payable under the scheme.
  Form-3: Intimation of Payment by the Declarant
  After making the payment, the declarant must file Form-3 to notify the designated authority of the completed payment.
  - Form-3 must be accompanied by proof that any related appeal, objection, writ, or petition has been withdrawn.
  Form-4: Order for Full and Final Settlement
  The designated authority issues Form-4 to confirm the full and final settlement of the tax arrears.
  - This form serves as the final order, detailing the settlement terms and confirming the payment made by the taxpayer.

Amount Payable under the DTVSV Scheme, 2024

The amount payable under the Direct Tax Vivad se Vishwas (DTVSV) Scheme, 2024 varies depending on the nature of the tax arrear and the timing of filing the appeal or declaration. The details are summarized below:

Sl. No.	Nature of Tax Arrear	Amount Payable on or before 31.12.2024	Amount Payable on or after 01.01.2025 but on or before the last date
1	Appeal filed after 31.01.2020, where the tax arrear consists of: (i) Disputed tax (ii) Interest chargeable/charged (iii) Penalty leviable/levied	100% of the disputed tax	Disputed tax + 10% of disputed tax
2	Appeal filed before 31.01.2020, where the tax arrear consists of: (i) Disputed tax (ii) Interest chargeable/charged (iii) Penalty leviable/levied	Disputed tax + 10% of disputed tax	Disputed tax + 20% of disputed tax
3	Appeal filed after 31.01.2020, where the tax arrear relates to: (i) Disputed interest (ii) Disputed penalty (iii) Disputed fee	25% of the disputed amount	30% of the disputed amount
4	Appeal filed before 31.01.2020, where the tax arrear relates to: (i) Disputed interest (ii) Disputed penalty (iii) Disputed fee	30% of the disputed amount	35% of the disputed amount

Procedures under the DTVSV Scheme, 2024

The following steps outline the procedure for availing benefits under the DTVSV Scheme:
1. Declaration and Withdrawal of Appeals
- The declarant must file a declaration with the designated authority in the prescribed form and manner.
- Once the declaration is filed, any ongoing appeals relating to the disputed income, interest, penalty, or fee before the CIT(A), ITAT, or Joint Commissioner (Appeals) will be deemed withdrawn from the date the designated authority issues a certificate.
- For appeals pending before the High Court or Supreme Court, the taxpayer must withdraw such appeals with the leave of the court after obtaining the certificate under Section 92(1), and submit proof of withdrawal to the designated authority.
- The taxpayer must also provide an undertaking confirming that no further legal remedies or claims will be pursued regarding the same tax arrear.
2. Determination and Payment of Amount Payable
- The designated authority shall determine the amount payable within 15 days of receiving the declaration and issue a certificate specifying the details of the tax arrear and amount due.
- The declarant must make the payment within 15 days of receiving the certificate and intimate the designated authority about the payment.
- The order determining the amount payable is final and conclusive, and the matters covered under it cannot be reopened in any other proceeding.
3. Consequences of Non-Compliance
- False Particulars: If any information in the declaration is found to be false or misleading, the declaration shall be treated as invalid.
- Violation of Conditions: Non-compliance with the terms of the scheme or the undertaking renders the declaration void.
- Revival of Proceedings: In cases of invalid or void declarations, any withdrawn legal proceedings shall be revived and reinstated as if no declaration had been filed.

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Vinod

Vinod is an accomplished legal writer who excels at translating complex legal concepts into clear, actionable insights. His work empowers entrepreneurs to navigate legal requirements with confidence and build compliant, sustainable businesses.

January 8, 2026