🔍 Introduction
On April 8, 2025, the Central Board of Direct Taxes (CBDT) issued Notification No. 32/2025 [S.O. 1650(E)], exercising powers under Section 89(1)(l) of the Finance (No. 2) Act, 2024. This notification sets April 30, 2025, as the final date for filing declarations under the Direct Tax Vivad se Vishwas Scheme, 2024. The declaration must be submitted to the designated authority in accordance with Section 90 of the said Act.
The notification serves as a final reminder and compliance trigger for taxpayers embroiled in prolonged tax disputes and seeking settlement under this beneficial scheme.
⚖️ Legal Framework: Vivad se Vishwas Scheme, 2024
The Direct Tax Vivad se Vishwas Scheme, 2024 (DTVSV 2024) is a dispute resolution scheme introduced through the Finance (No. 2) Act, 2024, aimed at reducing litigation in direct tax matters. It provides an opportunity for taxpayers to settle disputes by paying a certain portion of the disputed tax without incurring interest or penalties.
Key Legal References:
- Section 89(1)(l): Grants the Central Government the power to notify the last date for filing declarations.
- Section 90: Prescribes the procedure for filing declarations, verification, and issuance of certificate by the designated authority.
📅 What Does Notification No. 32/2025 State?
“…the Central Government hereby notifies under the Direct Tax Vivad se Vishwas Scheme, 2024, the 30th day of April, 2025 as the last date, on or before which a declaration in respect of tax arrear shall be filed by the declarant…”
Key Points:
- 30th April 2025 is the final date to file declarations.
- Applicable to tax arrears pending before any appellate forum.
- Declarations must be made electronically in prescribed form through the Income Tax Portal.
🧾 Eligible Disputes Under the Scheme
The DTVSV Scheme covers the following types of disputes:
- Appeals pending before CIT(A), ITAT, High Court, or Supreme Court.
- Reassessment orders, revision petitions or orders under DRP that are under challenge.
- Rectification applications or appeals filed by the Income Tax Department.
- Cases where assessment is completed but demand is unpaid, or where TDS defaults are challenged.
💸 Benefits to the Taxpayer
- Waiver of Penalty and Interest:
- The declarant is required to pay only the disputed tax.
- No interest, penalty, or prosecution if declaration is filed and settlement is made.
- Complete Closure of Litigation:
- All related appeals are withdrawn.
- Immunity from further tax liability on the declared issue.
- Time-bound Resolution:
- Designated authority to issue a certificate within 15 days from receipt of declaration.
- Final settlement to be made within 30 days of issuance of the certificate.
📝 Steps for Declaration Filing (Section 90)
- Login to e-Filing Portal: www.incometax.gov.in
- Navigate to ‘Vivad se Vishwas 2024’ under e-Services.
- Fill Form: Provide PAN, assessment year, appeal details, amount in dispute.
- Calculate and Pay: Based on the computation auto-generated.
- Submit Declaration: Along with payment proof.
- Wait for Certificate: Issued by designated authority under Section 90(1).
⚠️ Implications of Missing the Deadline
Failing to file the declaration by 30th April 2025 would:
- Result in the continuation of litigation.
- Potential loss of immunity from interest, penalty, and prosecution.
- Increase the cost and uncertainty of future tax liabilities.
👓 Practical Considerations for Taxpayers and Professionals
- Taxpayers with long-pending appeals or adverse CIT(A)/ITAT rulings should evaluate the cost-benefit of opting into the scheme.
- Advisors and CAs must proactively identify eligible clients and assist in computing liability, preparing declarations, and ensuring compliance.
- Ensure reconciliation of disputed amounts and appeal status, as mismatches can delay processing.
🔄 Comparison with Vivad se Vishwas, 2020
| Aspect | DTVSV 2020 | DTVSV 2024 |
|---|---|---|
| Applicability Cut-off | 31st Jan 2020 | 30th Nov 2023 |
| Last Date for Declaration | March 2021 (varied) | 30th April 2025 |
| Tax Payers Covered | Individual and Corporate | All Assessees |
| TDS Defaults | Covered | Covered |
📌 Conclusion
Notification No. 32/2025 is a final clarion call by the CBDT for taxpayers to utilize the Direct Tax Vivad se Vishwas Scheme, 2024. With an approaching deadline of April 30, 2025, it is critical for all stakeholders—individuals, corporates, and consultants—to take urgent action and evaluate open disputes for potential settlement.
The scheme not only reduces litigation burden on the Income Tax Department but also fosters a dispute-free compliance culture. Let this not be a missed opportunity.
Disclaimer: This article is intended for informational purposes and professional guidance. Readers are advised to consult their tax advisors for personalized advice.
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